GDPR Privacy Policy

1. Who We Are

Data controller: Avanza Digital, a registered sole proprietorship operating the Ace Velocity brand.

Business address: 60 Paya Lebar Road, #06-28, Singapore 409051.

Privacy and Data Protection Officer contact: Please submit privacy requests through the Ace Velocity Helpdesk. The helpdesk routes privacy matters to the Data Protection Officer.

Where the General Data Protection Regulation (GDPR) applies to our processing, this policy is intended to explain the relevant processing and your rights. The legal obligations applicable to a particular activity depend on the circumstances and applicable law.

2. Personal Data We Collect

The categories of personal data we collect depend on how you use the website and which features are enabled. They may include:

• Contact and form data: name, email address, and information you submit through contact forms, subscription forms, surveys, or other website forms.
• Email marketing data: subscription status, consent records, email delivery and engagement information, and unsubscribe or preference records.
• Technical and usage data: IP address, browser and device information, approximate location derived from IP address, referring pages, pages visited, timestamps, and diagnostic or security logs.
• Cookie and advertising data: cookie identifiers, consent choices, page interactions, campaign attribution, and information collected by analytics or advertising pixels, where enabled.
• Transaction and affiliate data: information needed to process a purchase or enquiry, transaction status, referral source, and affiliate attribution. Payment card details are generally handled by the relevant payment provider where that is how the transaction is configured.
• Communications: the contents of messages and the information needed to respond to requests or provide support.

Please do not send sensitive personal data through ordinary website forms unless it is specifically requested and appropriate safeguards have been explained.

3. Purposes and Legal Bases for Processing

Where the GDPR applies, we process personal data only where a valid legal basis applies to the particular purpose. Depending on the circumstances, these bases may include:

• Responding to enquiries and providing requested resources: taking steps at your request before entering into a contract, or performing a contract where applicable.
• Operating, maintaining, and securing the website: our legitimate interests in operating a reliable service, preventing abuse, and protecting systems, provided those interests are not overridden by your rights and freedoms.
• Email newsletters and promotional messages: consent where required by applicable data-protection and electronic-marketing laws. You may unsubscribe from marketing emails at any time.
• Analytics and audience measurement: consent where required for the technologies used, or another lawful basis where permitted by applicable law.
• Advertising, retargeting, and marketing measurement: consent where required for tracking technologies and processing, or another lawful basis only where permitted by applicable law.
• Transactions, accounting, and legal compliance: performance of a contract and/or compliance with legal obligations, as applicable.

Where we rely on legitimate interests, those interests should be relevant to the specific processing activity. We do not treat a general statement of legitimate interests as permission to carry out processing that requires consent.

4. Email Subscriptions and Marketing

If you subscribe to our emails, we use the information you provide to send the content or communications described at sign-up and to administer your subscription. Systeme.io provides email marketing functionality for Ace Velocity.

Where consent is the basis for sending marketing emails, you may withdraw it at any time by using the unsubscribe link in an email or submitting a request through the Ace Velocity Helpdesk. Withdrawal does not affect the lawfulness of processing before withdrawal. We may retain a minimal suppression record where necessary to respect your request not to receive further marketing.

Email service features may provide delivery, open, or click information. The specific tracking features in use depend on the platform settings.

5. Cookies, Pixels, and Similar Technologies

Our website uses or may use technologies needed to provide requested features, remember preferences, maintain security, and support forms. Analytics technologies and advertising pixels may also be used for audience measurement, campaign attribution, advertising, and retargeting.

For visitors in the EU/EEA, non-essential cookies and similar technologies will be used only after valid consent where applicable law requires prior consent. Consent should be specific, informed, freely given, and as easy to withdraw as to give. Refusing non-essential technologies should be possible without unnecessary friction.

A cookie-consent banner is provided on the website. Its settings and the website's tag configuration must be kept aligned so that non-essential analytics and advertising technologies do not run before the required consent is obtained. Visitors should be able to change or withdraw their choices using the available cookie controls.

Cookie use can vary by feature and provider. Browser settings may also allow you to control certain cookies, although blocking some technologies may affect website functionality.

6. Analytics, Advertising, and Social Platforms

Ace Velocity uses Google Analytics and Meta Pixel (Facebook/Instagram), and uses Google Ads or other advertising networks, for analytics, campaign measurement, advertising, or retargeting, depending on the tools enabled for a particular page or campaign.

These services may receive technical identifiers, event information, page URLs, and information about interactions with the website. Their processing is also subject to their own terms and privacy notices. Where required, tracking tags must respect visitors' consent choices and remain inactive until the relevant consent is obtained.

For more information, review the privacy information provided by Google and Meta. The precise data collected depends on the services and settings enabled.

7. Systeme.io, Forms, and Service Providers

We use Systeme.io to support website forms, landing pages, sales pages, and email marketing. We may also use third-party hosting, analytics, advertising, payment, affiliate, security, and customer-support providers to operate the website and deliver requested services.

These providers may process personal data on our behalf or act as independent controllers for certain activities, depending on their role and terms. We seek to use appropriate contractual and technical protections where a provider processes personal data for us. The exact recipients and their roles depend on the service used in each interaction.

8. Affiliate Links, Purchases, and Payments

Some pages may contain affiliate links. If you click an affiliate link, the destination website or affiliate network may use cookies or similar technologies to attribute a referral or purchase. The third party's own privacy policy and terms apply to its processing. Where our own website uses tracking technologies for affiliate attribution, we will obtain consent when required by applicable law.

If you purchase a product or service, order and payment information may be processed by the relevant seller, marketplace, or payment provider. The handling of payment-card details depends on the payment service and transaction flow. Review the relevant provider's privacy information before submitting payment information.

9. Who Receives Personal Data

Depending on your interactions with us, recipients may include Systeme.io, Google, Meta, advertising networks, affiliate networks, payment providers, website or security service providers, professional advisers, and public authorities where disclosure is legally required.

We share personal data for the purposes described in this policy and seek to limit disclosures to what is relevant for the relevant purpose. The roles of third-party providers depend on the service and processing activity.

10. International Data Transfers

Avanza Digital operates in Singapore, and our service providers may process personal data in Singapore and other countries. As a result, personal data may be transferred across national borders.

Where the GDPR applies and a transfer requires a specific safeguard, we will use a transfer mechanism permitted by applicable law, such as an applicable adequacy decision or appropriate safeguards. Information about applicable safeguards may be requested through the Ace Velocity Helpdesk.

11. How Long We Keep Personal Data

We retain personal data for as long as reasonably necessary for the purposes for which it was collected, including providing requested services, administering subscriptions, maintaining business and transaction records, protecting the website, resolving disputes, and meeting legal obligations. The period depends on the type of information, the purpose of processing, and any applicable legal requirements.

Where information is no longer needed, we will take reasonable steps to delete it or otherwise dispose of it securely, subject to any legal or legitimate record-keeping requirements.

12. Security

We use reasonable technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration, or disclosure. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Where legally required, we will address personal-data breaches and notify affected individuals or authorities as required by applicable law.

13. Your GDPR Rights

If the GDPR applies to our processing of your personal data, and subject to the conditions and exceptions in the law, you may have the right to:

• request access to your personal data and information about how it is processed;
• request correction of inaccurate or incomplete personal data;
• request erasure of personal data in circumstances provided by law;
• request restriction of processing in certain circumstances;
• object to processing based on legitimate interests and to processing for direct marketing;
• receive certain data in a portable format and request transmission to another controller where the legal conditions apply;
• withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing before withdrawal;
• lodge a complaint with a competent data-protection supervisory authority, particularly in the EU/EEA country of your habitual residence, place of work, or the place of the alleged infringement.

To exercise a right, contact us through the Ace Velocity Helpdesk. The request will be routed to our Data Protection Officer. We may ask for information reasonably necessary to verify your identity. We will respond within the time limit required by applicable law. Some rights are not absolute and may be subject to legal exceptions.

14. Profiling and Automated Decisions

Our use of analytics and advertising tools may involve audience segmentation, measurement, or profiling for advertising and retargeting. These activities may use information about website interactions to help measure campaigns or select audiences for advertisements.

We do not use this policy to claim that a particular automated decision-making system is in operation. If we introduce solely automated decisions that produce legal or similarly significant effects on individuals, we will provide the additional information and safeguards required by applicable law.

15. Children's Privacy

Our website is not intended to knowingly collect personal data from children in circumstances where such collection is unlawful. If you believe a child has provided personal data inappropriately, contact us through the Ace Velocity Helpdesk. We will review the request and take appropriate steps in accordance with applicable law.

16. Third-Party Websites

Our website may link to third-party websites, tools, products, or services. We do not control their privacy practices. Review the privacy notices of those third parties before providing them with personal data or interacting with their tracking technologies.

17. EU/EEA Representative

Avanza Digital has not currently appointed a representative in the European Union or European Economic Area. Depending on whether the GDPR applies to our activities and whether an exception is available, appointment of a representative may be required. Because our website uses analytics and advertising technologies, the applicability of this requirement should be assessed before relying on this policy for EU/EEA visitors. If a representative is required, this policy should be updated with that representative's identity and contact details once appointed.

18. Changes to This Policy

We may update this policy when our data practices, services, or legal obligations change. The updated version will be posted on this page. Where required, we will provide additional notice or obtain consent for material changes to processing.

19. Contact Us

For questions about this policy or to exercise your data-protection rights, contact Avanza Digital, operating the Ace Velocity brand, through the Ace Velocity Helpdesk. Privacy requests are routed to the Data Protection Officer.

Avanza Digital
Operating the Ace Velocity brand
60 Paya Lebar Road
#06-28, Singapore 409051