The Digital Green Fintech Group

Terms of Use

1. Governing Electronic Services

A. RECITAL 

  1. This Terms of Use Governing Electronic Services explains the terms and conditions that apply when you use any Electronic Services (as defined below) that may be provided by us.
  2. This Agreement will replace all previous terms and conditions relating to the provision of Electronic Services. Nothing in this Agreement will supersede or vary any term set out in other terms and conditions governing our relationship with you. This is especially so when you enter into separate agreements with us for the provision of Products & Services. The terms laid down therein shall apply.
  3. When you use any of our Electronic Services described in this Agreement, or authorise others to use them, you acknowledge and agree to the entire terms and conditions of this Agreement which forms the basis and entirety of the agreement between you and us.

B. DEFINITIONS

  1. The following terms shall bear the meanings set out in the table below:-
Accountshall mean any and all accounts which is accessed by you through Electronic Services and shall include any Account that you may be required to create for the access to any Products & Services.
Authorised Usershall mean any person(s) authorised by you or your joint account holder from time to time to use the Electronic Services in relation to your Account.
Channelshall mean any mode of access to our Electronic Services and shall include any Content.
Electronic Instructionsshall mean any electronic instructions, communications, instructions, orders, messages, data, information or other materials received by us through Electronic Services, which we reasonably believe come from you or your Authorised User. For the avoidance of doubt, we are under no obligations to verify the veracity and/or authenticity of such Electronic Instructions.
Electronic Servicesshall mean any services that we may offer to you from time to time via electronic means, including any modification thereof made by us (the scope and nature of which shall be determined at our sole discretion). They may include screening of wallet or transaction addresses, purchase, sale, subscription and/or redemption of any Products or the use of any other Services offered by us whether in or outside Singapore.
Electronic Transactionshall mean any transactions initiated or effected from your Account through Electronic Services.
Informationshall mean information regarding the money or other relevant particulars relating to you, or any Authorised User, or the Account or any Electronic Instructions.
Providershall include:- (1) any person (individual or non-individual) in Singapore or otherwise, which offer services or products, directly or indirectly through the Electronic Services; (2) any person (legal or natural) to whom we outsource certain functions or activities to allow us to operate our Electronic Services; (2) any government, regulator, law enforcement agency, financial institution, and ancillary service provider (for example, telecommunication, internet access, cloud network, logistics, facilities management, data centres, system hosting, call centres, equipment and software providers), agent or subcontractor involved in our provision of Electronic Services; and (4) our agents or storage or archival service providers for the purpose of making, printing, recording, mailing, storage, and/or filing any documents or items on which such Information appear.
Security Codesshall mean personal identification numbers, passwords, personal identifiers, biometrics identifiers, digital identifiers, other codes and verification procedures whether set by you or us that would allow you access to our Electronic Services.
“We”, “Us”, “Our” and “Ours”shall mean MetaComp and/or its Affiliates, including their successors and assignees, as the case may be.
“Affiliates”shall mean any related entities to MetaComp Pte. Ltd. (“MetaComp”) and may include but are not limited to its parent, sister and/or holding company.
“Agreement”shall mean these Terms and Conditions Governing Electronic Services.
“CAMP”shall mean an online client asset management platform owned and operated by us.
“Content”shall mean to any information, images, links, sounds, graphics, videos, software or other materials including quotes, news and research data that are available through our Electronic Services.
“Products & Services”shall include but are not limited to CAMP, any services or products offered through CAMP, any electronic wallets offered by us, any on-chain screening services provided by us (whether these are chargeable or otherwise).
“You”, “Your” or “Yours”shall mean everyone named on your Account, together, individually and includes you and/or any of your Authorised User as the case may be.

C. AUTHORIZED USER & USE

  1. Your use and access to our Electronic Services shall be subject to this Agreement. You shall be wholly responsible for all transactions made by you or, from our view, authorized by you, your Authorised User. We shall not have any responsibility to take any further steps to authenticate and/or determine the veracity of any Electronic Instructions issued through the Electronic Services.
  2. If your Authorised User accesses and/or uses our Electronic Services, we will deal with that person as if it was you using our Electronic Services and you shall ensure that each of your Authorised User is aware of and complies with this Agreement.
  3. In the event that you have authorised any person to give us Electronic Instructions on your behalf, you will be responsible for their acts and/or omissions, including any and all losses and/or damage arising from Electronic Payment which they may undertake. For the avoidance of doubt, such losses and/or damage shall also include any loss and/or damage that may be incurred as a result of any unauthorized, erroneous, or fraudulent Electronic Instructions issued by such person, whether or not such instructions were made with your knowledge or consent. You acknowledge and agree that we shall not be liable for any such losses and/or damages, except to the extent that they arise directly from our gross negligence, fraud, or willful misconduct.

    Furthermore, you shall indemnify and hold us harmless against any claims, liabilities, costs, or expenses (including legal fees) that may arise from the actions or omissions of any person whom you have authorized to issue Electronic Instructions on your behalf.

  4. We shall have the right to decline to proceed with any Electronic Instructions in the event that:-
    1. your Electronic Instructions are unclear, incomplete or inconsistent with other Electronic Instructions issued to us by you or Authorised User;
    2. the Electronic Instructions have lapsed, been rendered invalid due to failure to comply with applicable conditions or are cancelled by a regulatory or governmental body;
    3. the Electronic Instructions cannot be processed due to any disruptions that are beyond our reasonable control;
    4. processing the Electronic Instructions might expose us to legal action or censure from any government, regulator or law enforcement agency;
    5. any Electronic Instructions would cause you to exceed your applicable transaction or Account limits; and/or
    6. any Electronic Instructions would result in insufficiency of funds in your Account; without incurring any responsibility for loss, liability or expense arising out of so declining to act.
  5. We will treat all Electronic Instructions as final and unconditional when we receive them through the Electronic Services. This means we shall be entitled (but not obliged or obligated) to effect such Electronic Instructions without any need to seek your further consent and notice to you.

D. ACCESS TO ELECTRONIC SERVICES

  1. We may make Electronic Services available through different devices (for example, personal computers or mobile devices). The features of Electronic Services may vary and the access and features may differ depending on the type, system specifications and configuration of your device. To protect your Account, we may require a certain standard of specification, software version and such other technical requirements of your device used to access our Electronic Services.
  2. If you access Electronic Services outside of Singapore, your access may be limited and subject to the relevant laws and regulations of that country. We will not be responsible for any fees, charges and expenses or any other charges which may be imposed by your telecommunication or other service providers in connection with the use of Electronic Services.
  3. There may be circumstances where we may need to change the frequency and manner of use of our Electronic Services, transaction limits, operating hours and types of facilities and services. In certain situations, we may have to suspend the Electronic Services without giving you prior notice. Under such circumstances, we shall not be responsible for any inconvenience, loss, damage or injury suffered by you or any third party.

E. AUTHENTICATION SERVICE

  1. From time to time, we may introduce new or different forms of authentication service for you and/or your Authorized User’s authentication when you use our Electronic Services. We may replace the authentication service from time to time without prior notice to you.

F. RESPONSIBLE USE OF OUR ELECTRONIC SERVICES

  1. You shall ensure that the use our Electronic Services in accordance with all applicable laws, regulations, guidelines and within our reasonable expectations. You shall not use our Electronic Services for any purposes which are not authorised by us, wrongful and/or illegal purposes. In particular, you may not use our Electronic Services for the harvesting or extraction of any data. Where we are aware of any misuse of our Electronic Services by you and/or your Authorised User, we reserve the right to terminate or suspend our provision of Electronic Services to you immediately without any prior notice. In such instances, we shall not be liable for any loss suffered by you or any third party as a result of such termination or suspension.
  2. Where you or your Authorised User has misused our Electronic Services and caused loss and damage to you and/or any third party, you agree and undertake to fully indemnify us, our Affiliates, Providers and sub-contractors for such loss and damage suffered and shall pay such monies to us upon our demand.

G. RIGHT OF SET OFF

  1. We may set-off from your Accounts with us any fees, Goods and Services Tax (“GST”), loss, damage or expense suffered by us, as a result of our provision and/or your use of our Electronic Services. This means if you have not paid back the money you owe us under this Agreement or any other agreements that you may have entered with us for the use of our Products & Services, we may use the money in any of your accounts with us to partially or fully repay the money you owe. You agree that such exercise of our right of set off shall not require any further notice.

H. SECURITY & AUTHENTICATION

  1. For security and authentication purposes, you may be required to create Security Codes in connection with your Accounts and/or Electronic Instructions. You are advised to ensure that your Security Codes and email accounts are sufficiently secure and not easily compromised.
  2. To ensure that your Account is protected, you agree to:-
    1. notify us immediately if you change your mobile number or email/mailing address which are used to generate and/or receive any Security Codes;
    2. notify us immediately if you have lost any of your Security Codes or your device used to generate and/or receive Security Codes or email addresses have been compromised;
    3. to tell us immediately if any Authorised User to whom the Security Code is given is no longer authorised to use the Electronic Services;
    4. not disclose your Security Codes to any third party;
    5. to ensure that your Security Codes are kept in a secure manner and not accessible by any third party;
    6. to take due care of the devices that you use to generate or receive Security Codes, access online banking and email addresses and ensure that they are not vulnerable to unauthorised access;
    7. not to use any equipment, device, software or email address which you know or have reason to suspect contains any viruses, malicious code or damaging components which may interfere with or compromise your use of the Electronic Services; and/or
    8. not to install, or cause to be installed (for example clicking on suspicious links), any malware or viruses that would result in your devices, email addresses or Security Codes being compromised by any third party.
  3. If you discover or suspect any unauthorised or erroneous transactions from or to your Account, you must notify us immediately. Upon such discovery, you agree to take such steps to protect your Account, including changing any Security Codes, passwords to your email accounts and reporting such incidents to us immediately.
  4. Where we are of the view that your Account or your Security Codes might have been compromised, in order to protect your Account, we may:-
    1. require that you identify yourself by alternative means;
    2. require any Electronic Instruction to be confirmed through alternative means (in writing given in person at a branch, etc.); and/or
    3. refrain from acting promptly upon any Electronic Instructions in order to confirm any Electronic Instructions or your identity.

In such circumstances, your Electronic Instructions might not be processed within expected periods and we will not be responsible for any inconvenience, loss, damage or injury suffered by you or any third party.

  1. In respect of unauthorised or erroneous transactions from your Account, we shall do our best to help you, but we may not always be able to reverse such transactions. To assist us in our investigations and recovery efforts, we may:-
    1. request that you report unauthorised or erroneous transactions to the relevant law enforcement and/or regulatory authorities and provide us with such report; and/or
    2. require information relating to such unauthorised or erroneous transactions, including how such transactions occurred; and/or
    3. require you to report to relevant law enforcement and/or regulatory authorities as the case for any necessary directions and/or assistance.

If you are unable to or decline to provide the requested information above, this would have a negative impact on our recovery efforts.

  1. Where such erroneous or unauthorised transactions were a result of your authorisation (whether as a result of fraud or otherwise), recklessness or mistake, we will not be liable to you for such losses. Recklessness would include any failure by you to comply with this Agreement.
  2. In respect of unauthorised or erroneous transactions to your Account, where we are satisfied that such credited sums to your Account was in fact unauthorised or erroneous (including any mistake made by us), we have the right to deduct such sums from your Account without your prior consent. We shall however notify you of such deduction.
  3. We shall retain the right to decline providing you with any Electronic Services where we have reasons to believe that you do not intend to use our Electronic Services responsibly. In this case, we shall not be obligated to provide you with any reasons whatsoever for such refusal to provide.

I. WARRANTIES, DISCLAIMER AND LIMITATIONS

  1. We do not provide any warranty of any kind of:-
    1. our Electronic Services, including warranties of accessibility, quality, provision or performance of any goods or services;
    2. our Content, including warranties of accuracy, adequacy, currency or reliability;
    3. our hyperlinks to any other websites or content, if any, which are not an endorsement or verification of such websites or content.
  2. We will not be responsible for any loss suffered by you arising from or in connection with your use of Electronic Services even if we are advised of, or otherwise might have anticipated, the possibility of such loss, damage or expense. In particular, we will not be liable to you for any loss as a result of:-
    1. any Electronic Services not being available due to system maintenance or breakdown/non-availability of any network;
    2. the non-delivery, delayed delivery, misdirected delivery or the non-receipt of any Electronic Services.
    3. any non-processing or delay in processing of Electronic Instructions by us or by any Provider through whom your Electronic Instructions are transacted;
    4. inaccurate or incomplete Content, reliance on or use of the information provided on any Channel for any purpose;
    5. any disclosure of any Information which you have consented to us collecting, using or disclosing or where such collection, use or disclosure is allowed under the applicable laws in Singapore;
    6. any unauthorised and/or unlawful access to our machines, data processing system or transmission link;
    7. any act of force majeure such as acts of God, war or warlike hostilities, civil commotions, riots, blockades, embargoes, sabotage, strikes, lock-outs, fire, flood, shortage of material or labour, delay in deliveries from sub-contractors; and/or
    8. any event outside our control.

J. OUR RECORDS

  1. Our records and any records of the Electronic Instructions including Electronic Services operations maintained by us or by any relevant person authorised by us shall be binding and conclusive on you for all purposes whatsoever. They shall be final and conclusive evidence of any Electronic Instructions, information and/or data transmitted using Electronic Services.
  2. When we deal with you, we will treat all such records as final evidence and you shall not challenge or dispute the admissibility, reliability, accuracy or the authenticity of the contents of such records merely on the basis that such records were incorporated and/or set out in electronic form or are produced by or were the output of a computer system. You agree to waive any of your rights (if any) to so object. This provision shall also apply to all records maintained by a Provider designated by us.

K. FEES

  1. We may charge and revise fees for our services (for example, processing and transaction fees relating to our Electronic Services). In most cases, we shall endeavor to notify you in advance of such changes before they become effective, unless it is not practicable to give such advance notice.
  2. For certain Electronic Services, we may share fees, brokerages, commissions and other charges with our Provider. We are not required to account to you for all or any part of these sums.
  3. If GST is charged on any payment, you shall pay such GST in addition to all sums payable. You agree to indemnify us against any payments that we are required by law to collect and make in respect of such GST.

L. TERMINATION

  1. We may stop or suspend any of our Electronic Services immediately without giving any reason. This includes limiting or replacing the Electronic Services as we may tell you from time to time.
  2. If we need to end this agreement (and close your Accounts linked to our Electronic Services), we may do so at any time without giving any reason or advance notice to you. We shall notify you as soon as practicable by any notification method, including through Electronic Services, local newspapers, displays at our branches or media publications. Such termination shall be effective on and from the date specified in the notice.
  3. Unless notified by us in writing and/or otherwise provided in the agreements for relevant Products & Services, you may terminate your use of any Electronic Services by giving us seven (7) days advance written notice. Terminating your use of the Electronic Services shall not affect any rights or obligations accrued before the effective termination date.

M. INTELLECTUAL PROPERTY

  1. Without our prior written consent, no part or parts of the Channel or the Electronic Service or any Content may be reproduced, distributed, republished, displayed, broadcast, hyperlinked, transmitted, adapted, modified to create derivative works or otherwise commercially exploited in any manner or by any means or stored in an information retrieval system.
  2. You shall be permitted to view, print or use the Content for personal, non-commercial use only, provided that you do not modify the Content and that you retain all copyright notices and other proprietary notices contained in the Content.
  3. Trademarks, service marks, and logos (the “Trade Marks”) used and displayed on or through the Channel or the Electronic Services are registered and unregistered Trade Marks of ours and others. You agree not to use any Trade Marks displayed on or through the Channel or the Electronic Service, without our written permission.

N. USE OF THIRD PARTIES

  1. We reserve the right to use any Provider, subcontractors and/or agents on such terms as we deem appropriate.

O. OTHER TERMS

  1. This Agreement shall be governed by Singapore law and shall be subject to the exclusive jurisdiction of the Singapore courts.
  2. No failure to exercise, nor any delay in exercising, on our part any right or remedy under this Agreement will operate as a waiver thereof, nor shall any single or partial exercise of any right or remedy prevent any further or other exercise thereof or the exercise of any other right or remedy. Our rights and remedies in this Agreement are cumulative and not exclusive of any other rights or remedies provided by law.
  3. If any term of this Agreement is unlawful or unenforceable under any applicable law, it will, to the extent permitted by such law, be severed from this Agreement and rendered ineffective where possible without modifying the other terms of this Agreement.
  4. In the event of any contradiction or inconsistencies with other terms, this Agreement shall prevail in respect of your use of Electronic Services and resolution of any disputes or issues arising out of your use of our Electronic Services. Where the dispute or issues relates to your Accounts or terms pertaining to the use or provision of the Products & Services, the terms in those agreements executed between us and you shall prevail.

2. Privacy Policy

The “Alpha Ladder Group” is committed to protecting and respecting your privacy.

For the purposes of this Policy and the Personal Data Protection Act 2012 (“the Act”), “Personal Data” as defined in section 2 of the Act 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 the organization has or is likely to have access.

The Alpha Ladder Group consists of the following entities:-

EntityRegistered AddressContact Email
Alpha Ladder Group Pte. Ltd.168 Robinson Road, #19-15, Capital Tower, Singapore 068912dpo@mvgx.com
Alpha Ladder Finance Pte. Ltd.
MetaComp Pte. Ltd.
MVGX Tech Pte. Ltd.

References in this Policy to the “Alpha Ladder Group”, “company”, “we”, “us” or “our” shall refer to any one of the aforesaid entities as the case may be while references to “you” shall mean any person subject to any persons.

This Policy (together with any published terms of use or terms of services together with and any other documents referred to on it) shall set out the basis on which any Personal Data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it. By visiting, accessing or using any Alpha Ladder Group website and associated application program interfaces or mobile applications (the “Alpha Ladder Group Platform”), you (a) acknowledge that you have the right, capacity and authority to accept this Policy; (b) acknowledge that you have read and understood this Policy and (c) consent to the policies and practices outlined in this Policy.

A. COLLECTION OF DATA

  1. Information We May Collect from You
    1. Information you give us. You may give us information about you by filling in forms on our website or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our website and when you report a problem with our website. The information you give us may include your name, address, e-mail address and phone number.
    2. Information we collect about you. Regarding each of your visits to our website we may automatically collect the following information:
      1. technical information, including the Internet protocol address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
      2. information about your visit, including the full Uniform Resource Locators clickstream to, through and from our website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
      3. Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that Personal Data that it may be shared internally and combined with Personal Data collected on this website. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
  2. Cookies
    1. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. For detailed information on the cookies we use and the purposes for which we use them for, please visit our Cookies Policy published on our websites.

B. USE OF DATA

  1. We use information held about you in the following ways:
    1. Information you give to us. We will use this information:
      1. to carry out our obligations arising from any contracts entered between you and us and to provide you with the information, products and services that you request from us;
      2. to provide you with information about other services that we offer that are similar to those that you have already used or enquired about;
      3. to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or phone) with information about services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your Personal Data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your Personal Data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your Personal Data (the [order form OR registration form]);
      4. to notify you about changes to our services;
      5. to ensure that content from our website is presented in the most effective manner for you and for your computer;
      6. Other uses include but are not limited to, the following:-
        1. to help us identify you and any accounts you hold with us;
        2. administration;
        3. research, statistical analysis and behavioural analysis;
        4. customer profiling and analysing your consumer preferences;
        5. marketing;
        6. fraud prevention and detection;
        7. billing and order fulfilment;
        8. credit scoring and credit checking;
        9. customising our website and its content to your particular preferences;
        10. to notify you of any changes to our website or to our services that may affect you;
        11. security vetting;
        12. improving our services.
    2. Information we collect about you. We will use this information:
      1. to administer our website and for internal operations, including troubleshooting, data analysis, testing, research and statistical purposes;
      2. to improve our website to ensure that content is presented in the most effective manner for you and for your computer;
      3. to allow you to participate in interactive features for our service, when you choose to do so;
      4. as part of our efforts to keep our website safe and secure;
    3. Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

C. DISCLOSURE OF YOUR INFORMATION

  1. We may share your personal information with any member of the Alpha Ladder Group, which includes our subsidiaries, holding companies and companies under common control including their respective contractors, affiliates, employees or representatives, as it may be necessary for the provision of any products and/or services to you.
  2. We may share your information with selected third parties including but not limited to:
    1. business partners and vendors for the performance of any contract we enter into with them or you or permitted by law or professional standards including, for example, payment processing, customer support, information technology, data analytics, data processing, network infrastructure, storage and tax reporting;
    2. entities in connection with corporate transactions involving Alpha Ladder Group, including any financing, acquisition or dissolution proceedings which involve disclosing a certain portion or all of our business or website;
    3. should there be a need, credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you;
    4. in the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets; or
    5. if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply our any of our terms and conditions relating to any products or services that we are providing to you or any terms under any agreements we have entered into; to protect our rights, property, or safety, our customers, or others. This includes exchanging information with other companies for the purpose of our anti-money laundering and counter-terrorism financing obligations.
  3. Sending Information to Other Countries
    1. Alpha Ladder Group operates a global business and Personal Data may be stored and processed in any country where we have operations or where we engage service providers. We may disclose information to third party storage providers or affiliates that are located outside your country of residence or disclose to third-party storage providers or affiliates that are located outside your country or residence.
    2. We may transfer Personal Data that we maintain about you to recipients in countries other than the country in which the Personal Data was originally collected. Those other countries may have data protection or privacy rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Privacy Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data. By communicating electronically with us, you acknowledge and agree to your Personal Data being processed in this way.

D. STORAGE OF YOUR INFORMATION

  1. How We Store Your Personal Data
    1. We recognise the importance of securing the Personal Data of our users. We take steps to ensure that your Personal Data is protected from misuse, interference or loss, and unauthorised access, modification or disclosure. Your Personal Data is generally stored in our or our affiliates’ computer databases and/or with third party storage providers.
  2. Where We Store Your Personal Data
    1. The Personal Data that we collect from you may be transferred to, and stored at, a destination outside Singapore. It may also be processed by an employee operating outside Singapore who work for us or for one of our affiliates. Such employee may be engaged in, among other things, the provision of support services. By submitting your Personal data, you agree to this transfer, storing or processing. We will generally take appropriate steps to ensure that the recipient of the Personal Data is bound by legally enforceable obligations to provide to the transferred Personal Data a standard of protection that is at least comparable to the protection under the PDPA (“Comparable Standard”). To this end, we will ensure that at least one of the following measures is implemented:
      1. you consent to such transfer after you have been given a reasonable summary in writing of the extent to which your Personal Data to be transferred will be protected to a Comparable Standard (including but not limited to this Policy);
      2. the overseas recipient of such Personal Data is bound by law, contract, binding corporate rules or any other legally binding instrument to protect the transferred Personal Data to a Comparable Standard; and/or
      3. the overseas recipient of such Personal Data holds a valid certification under the Asia Pacific Economic Cooperation Cross Border Privacy Rules (“APEC CBPR”) System or the Asia Pacific Economic Cooperations Privacy Recognition for Processors (“APEC PRP”) System.
    2. Where the above measures are not feasible, we may still proceed with the transfer of your Personal Data from Singapore to a recipient outside of Singapore if:
      1. the transfer is necessary for a use or disclosure that is in your vital interests or in the national interest and we have taken reasonable steps to ensure that the Personal Data will not be used or disclosed by the recipient for any other purpose; and/or
      2. the transfer is reasonable necessary for the conclusion or performance of a contractual obligation between you and us.
    3. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. You should not share your password with anyone.
    4. We cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
    5. If we have credible grounds to believe that a data breach has occurred, we will take steps to assess if the data breach is notifiable under the PDPA. Once we assess that a data breach is a notifiable data breach, we will notify the Personal Data Protection Commission of Singapore and you as soon as it is practicable. If we share your Personal Data with our third party service providers, we will require them to process it strictly in accordance with our instructions or as otherwise required by the PDPA.
  3. Retention of Personal Data
    1. We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as requested or permitted by applicable laws.
    2. We will cease to retain your Personal Data, or remove the means by which the Personal 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 example, we are subject to certain anti-money laundering laws and/or regulations which require us to retain records we used to comply with our client identification and due diligence obligations for an additional period after our business relationship with you has ended.
  4. Information Security
    1. We have put in place appropriate information security measures to prevent your Personal Data from being accidentally lost, accessed, altered, disclosed, used or destroyed in an unauthorized way (or other similar risks). We take various measures to ensure information security, including encryption of the Alpha Ladder Group Platform communications; required two-factor authentication for all sessions; periodic review of our Personal Data collection, storage, and processing practices; and restricted access to your Personal Data on a need-to-know basis for our employees and vendors who are subject to strict contractual confidentiality obligations.

E. YOUR RIGHTS

  1. Access to Your Information and Accuracy of Your Information
    1. The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act.
    2. If you would like to request for a copy of some or all of your Personal Data, please send an email to us. We will require identity verification and specification of what information is required before providing you with access. Where permitted by law, we reserve the right to charge a reasonable administrative fee for this service. We will provide access within thirty (30) calendar days of your request. In exceptional circumstances, we reserve the right to deny you access to your information and may provide you with an explanation as required by applicable laws.
    3. We may also request you to update your Personal Data. We want to ensure that your Personal Data is accurate and up to date and seek your assistance to ensure that such information is current, complete and accurate. If any of the information that you have provided to us changes, please let us know the correct details by sending an email to us.
    4. You may ask us, or we may ask you, to correct information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate.
  2. Marketing and Opting Out
    1. Alpha Ladder Group may also wish to provide you with information about special features of our website or any other service or product we think may be of interest to you. If you prefer not to receive any further direct marketing communications from us or our business partners, please contact us any time to opt-out.
    2. We may also want to provide you with related information from third parties we think may be of interest to you. If you would rather not receive this information, please contact us to inform us otherwise.
    3. We may also provide your information to carefully selected third parties whose products or services we believe may be of interest to you. If you do not wish us to disclose your information in this way, please contact us to inform us otherwise.

If you would like to withdraw your consent to the above, please contact us at the contact details stated above.

F. CHANGES TO OUR PRIVACY POLICY

  1. You shall be deemed to have agreed to the terms under this Policy unless you specifically notify us by email.
    1. We may revise this Policy from time to time without any prior notice. Any changes we may make to our privacy policy in the future will be posted on this page and you shall be deemed to have agreed to any such changes should you continue to use any of the Alpha Ladder Group’s products and services.
    2. It is your responsibility to check back this page frequently to see any updates or changes to our Policy.

G. EXTERNAL WEBSITES

  1. The Alpha Ladder Group Platform contains links to external websites. We make no representations as to the quality, suitability, functionality or legality of the material on external websites that are linked to, or to any goods and services available from, such websites. The material is only provided for your interest and convenience. We do not monitor or investigate such external websites and we accept no responsibility or liability for any loss arising from the content or accuracy of the material and any opinion expressed in the material should not be taken as our endorsement, recommendation or opinion. This Policy does not extend to your use of such external websites. You are advised to read the privacy policy or statement of such external websites before using them.

3. Cookie Policy

A. INTRODUCTION

  1. This Cookies policy (“this Policy”) explains how “Alpha Ladder Group”, “we”, “our”, “us”) uses cookies on our website. It explains the types of cookies we use and why and also how you can manage your cookie preferences.
  2. For the avoidance of doubt, the Alpha Ladder Group consists of the following entities:-
    1. Alpha Ladder Group Pte. Ltd.;
    2. Alpha Ladder Finance Pte. Ltd. ;
    3. MetaComp Pte. Ltd.;
    4. MVGX Tech Pte. Ltd.; and
    5. Any other entities that may form part of the Alpha Ladder Group from time to time.

For the avoidance of doubt, reference to Alpha Ladder Group, we our or us may mean any or all of the Alpha Ladder Group entities as the case may be.

  1. This Policy should be read alongside our Privacy Policy, which explains how your personal data is used and processed by us.

B. WHAT ARE COOKIES?

  1. Cookies are text files containing small amounts of information which are downloaded to your computer (or other electronic device) when you visit a website. Cookies are then sent back to the originating web domain on your subsequent visits to that domain. Most web pages contain elements from multiple web domains so when you visit any of the Alpha Ladder Group’s website your browser may receive cookies from various sources.
  2. Cookies are useful because they allow a website to recognise a user’s device. They allow you to navigate between web pages efficiently, remember preferences and analyse how you use websites and online services. They can also be used to tailor advertising to your interests through tracking your browsing across websites.

C. USE OF COOKIES

  1. A cookie is a small text file which is created onto your computer (or other electronic device) when you access our website.
  2. The information we obtain from our use of cookies will not usually contain your personal data. Although we may obtain information about your computer or other electronic device such as your IP address, your browser and/or other internet log information, this will not usually identify you personally. In certain circumstances we may collect personal information about you, but only where you voluntarily provide it.
  3. We use cookies on our website to:-
    1. manage the signing up process and general administration when you create an account with us;
    2. remember your user details for future correspondence when you submit data through a form;
    3. remember your preferences when viewing our website;
    4. remember when you are logged in to your account, which prevents you from having to log in every time you visit a new page;
    5. record and store your acceptance of any of our terms of services (including but not limited to our Privacy Policy and this Policy); collect statistical information about users of our websites (for example, time spent on each page and which links our users choose to click);
    6. collect statistical information about users of our website (for example, time spent on each page and which links our users choose to click);
    7. from time to time when we offer surveys and questionnaires to understand our user base more accurately, such surveys and questionnaires may use cookies to remember who has already taken part in a survey to provide you with accurate results after you change pages;
    8. ensure compliance with our regulatory and anti-money laundering requirements, and to ensure your account security has not been compromised by detecting irregular, suspicious, or potentially fraudulent account activities.

D. CONSENT

  1. If you visit our website when your browser is set to accept cookies, we will interpret this as an indication that you consent to our use of cookies. If you decide in the future not to let us use cookies, you can modify the settings of your browser to reject cookies or disable cookies completely.

E. THIRD PARTY WEBSITES

  1. This Policy does not apply to, and we are not responsible for, the privacy practices of third party websites, which may be linked to or accessible through our website.

F. HOW TO DISABLE COOKIES

  1. If you want to disable cookies on your web browser, you can change your browser settings so that cookies are not accepted. However, please note that because cookies are used throughout our website, disabling them may prevent you from using certain parts of our website. For further information about cookies and how to disable them, please visit: https://www.aboutcookies.org or https://www.allaboutcookies.org.

G. CONTACT US

  1. If you have any questions about this Policy, please contact us via through our email addresses found in our Privacy Policy.

H. CHANGES TO THIS POLICY

  1. We may update this Cookies policy and we would encourage you to review the policy from time to time to stay informed of how we are using cookies.

         This Policy was last updated on 30 April 2025.

168 Robinson Road #19-15, Capital Tower Singapore 068912

Alpha Ladder Group (formerly MVGX Holdings) is a leading Digital Green Fintech Group shaping the future of financial innovation, financial technology, and sustainable technology. The subsidiaries of Alpha Ladder Group are duly regulated by the Monetary Authority of Singapore ("MAS"), including MetaComp Pte. Ltd. ("MetaComp"), Alpha Ladder Finance Pte. Ltd. ("ALF"), and Asia Green Fund Management Pte. Ltd. ("AGFM"). MetaComp holds a Major Payment Institution licence. ALF holds a Capital Markets Services licence in custodial services, dealing in capital markets services, and a Recognised Market Operator licence. AGFM holds a Capital Markets Services licence in fund management.

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