Full Privacy Policy
uSMART Securities (USA) LLC. and its respective subsidiaries and affiliates (collectively, "uSMART", "we", "our" or "us") have entered into a client agreement with you ("Agreement") for the products and services we provide. This Privacy Policy ("Policy") is part of the Agreement and describes our practices for collecting, using, disclosing, and protecting your information.
If you do not agree to the processing of your personal information as described in this policy, please do not provide your information and stop using our services. By using the Services, you acknowledge you have read and understood this Policy.
1. Processing Personal Information
We need to collect personal information to provide our services to you. If you do not provide the requested information, we may not be able to open or maintain your account. The table below outlines what we process and why.
| Information Category | Examples | Primary Purpose |
|---|
| Identity & Contact Information | Name, Date of Birth, Postal Address, Phone Number, Email Address, Social Security Number (SSN), Passport/ID details, Nationality. | To create and verify your account, comply with "Know Your Customer" (KYC) and Anti-Money Laundering (AML) regulations, and contact you. |
| Account Data | Username (uSMART ID), password, profile picture, personal signature. | To facilitate your secure use of the services. |
| Financial Information | Bank account details, information on assets and income, investment objectives, tax information. | To assess your suitability for our products, process funding and withdrawals, and for tax reporting purposes. |
| Biometric Information | Facial features collected during face recognition scans. | For secure identity verification during account opening and for high-risk operations, shared with third-party vendors for verification. |
| Device Information & Identifiers | IP Address, device type, OS, screen resolution, language settings, browser type, IDFA, ADID. | To ensure service integrity, security, fraud prevention, and optimize user experience. |
| Usage & Transactional Information | Trading activity, orders, positions, account balances, clicks, browsing history, searches, favorites within the app. | To execute your trades, provide account statements, and improve our services. |
| Community & Support Data | Messages, images, videos, and comments you post in the community; your customer service requests and communication history. | To facilitate community interaction and respond to your support requests. |
| Location Data | Approximate location derived from IP address, or precise location via GPS (with your permission). | To ensure the provision of services is secure and lawful for your region. |
If you disclose any Personal Information relating to other individuals to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Policy.
2. Usage and Purpose of Your Personal Information
We use your Personal Data for the following purposes:
- Service Provision: Executing your transaction orders, carrying out your instructions, and providing all related financial services and products, including account opening, trading, and clearing.
- Compliance & Risk Management: Conducting credit inquiries, background checks, and identity verification; complying with all applicable laws, regulations, and rules from governmental or regulatory authorities (e.g., SEC, FINRA), exchanges, and clearing houses, both within and outside the US; preventing or detecting money laundering, terrorist financing, or other unlawful activities.
- Service Improvement: Analyzing user behavior to improve our products, services, and overall user experience; designing new financial services or products.
- Third-Party Integration (SDKs): We use third-party Software Development Kits (SDKs) to provide certain functions. These may include instant messaging, app performance analysis, crash reporting, and advertising monitoring. These third parties' use of your data is governed by their own privacy policies. For a detailed list, please see our Third-Party SDKs List. All vendors and/or providers for the aforesaid Third-Party SDKs are contractually obligated to comply with our data protection standards and all applicable U.S. laws and regulations. They are restricted from using your personal information for any purpose other than for the specific services we have contracted them to perform.
- Marketing: With your consent, we may use your name, contact information, and service usage history to market capital markets products and services that may be of interest to you. You can opt-out at any time.
3. Sharing of Personal Information
To the extent required to supply our services, we will share certain personal information with the following parties (both within and outside the US):
- Our Affiliates: Entities within the uSMART Group who process personal information as part of providing the services and for purposes described in this Policy.
- Essential Financial Partners: Any foreign or local exchanges, clearing houses, execution brokers, custodians, and nominees required to place, transact, clear, and hold your trades and assets.
- Third-Party Service Providers: These include providers for cloud hosting, data analysis, payment processing, identity verification (AML/KYC checks), customer service, IT infrastructure, and other administrative or professional services. All Third-Party Service Providers are contractually obligated to comply with our data protection standards and all applicable U.S. laws and regulations. They are restricted from using your personal information for any purpose other than to provide the services we have contracted them to perform.
- Governmental and Regulatory Authorities: Any foreign or local governmental, regulatory, supervisory, tax, or law enforcement authorities, where we are legally required to disclose information to comply with laws, regulations, subpoenas, or investigations.
- Credit & Debt Agencies: Credit reference agencies for conducting credit checks, and debt collection agencies in the event of default.
- Other Users or the Public: If you post content to our community forums, that information will be publicly available.
- In Connection with a Sale or Business Transaction: We may disclose or transfer your information to a third party in the event of any reorganization, merger, sale, or joint venture.
4. Cookies and Other Tracking Technologies
We use cookies, pixel tags, and similar technologies to operate and improve our services.
- Cookies: These are small pieces of information stored on your computer. They help us with security, navigation, displaying information effectively, and personalizing your experience. Most browsers allow you to decline cookies, but doing so may cause inconvenience in using our services.
- Pixel Tags (Web Beacons): These help us track user actions, measure the success of our marketing campaigns, and compile usage statistics.
- Analytics: We use services like Google Analytics to understand how our services are used. These services may collect information about your use of our and other websites. You can learn about Google’s practices and opt-out at their respective websites.
- IP Address: Your IP address is logged automatically for calculating usage levels, diagnosing server problems, and administration. We may also derive your approximate location from it.
5. Storage and Transfer of Personal Information
Our servers are located in [Please specify your US server locations] and Singapore. Our support, affiliates, and third-party partners are located globally. Therefore, your personal information may be transferred to, stored, and processed in countries outside of your jurisdiction of residence. We will implement appropriate safeguards (such as Standard Contractual Clauses where required) to ensure that your personal information receives a standard of protection comparable to that under your local laws.
6. Retention of Personal Information
We will retain your personal information for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. For example, financial services regulations (e.g., under the Securities Exchange Act of 1934) require us to keep records for several years even after an account is closed. Once retention is no longer necessary for legal or business purposes, we will cease to retain your Personal Data or anonymize it.
7. Security
We use reasonable organizational, technical, and administrative measures to protect personal information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately.
In the event of a data breach that compromises the security of your personal information, we will take immediate steps to contain and investigate the incident. Our breach response protocols include identifying the affected data, taking remedial measures, and assessing the risk of harm. Our Data Protection Officer is responsible for overseeing our incident response plan and compliance with notification obligations.
Should a breach be determined to pose a significant risk of harm or as otherwise required by law (such as under SEC Regulation S-P), we are committed to notifying affected customers without undue delay, and in any event within thirty (30) calendar days of confirming the breach. For any security-related concerns or to report a potential incident, please contact our Data Protection Officer at dpo@usmart.sg.
8. Data Subject Rights
Depending on your jurisdiction, you have certain rights regarding your personal information. These may include:
- Right to Access: You may have the right to request access to your personal information and receive information about how we have used or disclosed it.
- Right to Correction: You may request that we correct any inaccuracies in your personal information. You can update most information directly through the App settings.
- Right to Withdraw Consent: You may withdraw your consent for our collection, use, and disclosure of your personal information. Please note that withdrawing consent may result in our inability to continue providing services to you, potentially leading to the closure of your account.
- Right to Deletion: You may have the right to request we delete your personal information, subject to our legal and regulatory retention obligations.
- Right to Opt-Out of Sharing with Non-Affiliates: You have the right to direct us not to share your personal information with non-affiliated third parties, except as permitted by law (for example, to process your transactions or maintain your account). You may exercise this right by contacting us at dpo@usmart.sg.
To exercise the aforesaid rights, please contact us at dpo@usmart.sg. For your protection, we may need to verify your identity before implementing your request.
9. Account and Data Deletion
If you wish to close your uSMART trading account, please contact us at support@usmart.sg. Upon your request, we will close your account. However, notwithstanding anything to the contrary hereunder, we will retain your information in accordance with our regulatory obligations. After the mandatory retention period has expired, your personal information will be permanently deleted or anonymized.
10. Use of Services by Minors
The services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from them.
11. Updates to this Privacy Policy
We may review and update this Policy from time to time. The "Last Updated" legend at the top indicates when it was last revised. Your use of the Services following these changes means that you accept the revised Policy.
In accordance with U.S. federal law and any other applicable laws and regulations, we will provide U.S. customers with a notice of our privacy policy annually. We will deliver this notice to you by mail or email, as you have elected to receive communications from us.
12. Jurisdiction-Specific Terms
jurisdictions’ laws contain additional terms for users of the Services, which are set out in this section. If you are a user located in a jurisdiction with data protection laws that grant you specific rights not described in this Policy, please contact us. We will honor your rights in accordance with applicable law.
California
This section applies to California residents covered by the California Consumer Privacy Act of 2018 and any amendments thereto (“CCPA”).
- Collection and Disclosure of Personal Information: Over the past 12 months, we have collected and disclosed the categories of personal information as described in the "Processing Personal Information" chart above. We collect this information to provide and improve the services, for security and verification, and to comply with legal obligations.
- No Sale of Personal Information: In the past 12 months, we have not "sold" Personal Information of California residents within the meaning of “sold” in the CCPA.
- Rights under the CCPA: If you are a California resident, you have the right to:
1. Request Disclosure: Request we disclose to you, free of charge, the categories and specific pieces of personal information we have collected about you, the sources of that information, the purpose for collecting it, and the categories of third parties to whom we disclosed it over the past 12 months.
2. Request Deletion: Request we delete personal information we collected from you, unless an exception under the CCPA applies (e.g., to comply with a legal obligation).
3. Right to Opt-Out of Sale or Sharing: You have the right to direct us not to sell or share your personal information. For the avoidance of doubt, while we do not sell personal information for monetary value, some sharing with such third-party service providers as aforesaid for purposes like service functionality may be considered a “sale” or “sharing” under the CCPA.
4. Non-Discrimination: Be free from unlawful discrimination for exercising your rights under the CCPA.
How to Exercise Your Rights: California residents may exercise their rights by contacting us at dpo@usmart.sg. We aim to fulfill all verified requests within forty-five (45) calendar days.
To exercise your right to opt-out of the sale or sharing of your personal information, please visit our “Do Not Sell or Share My Personal Information” page [please insert the link here]. You may also broadcast the user-enabled Global Privacy Control (GPC) to opt-out for each participating browser system that you use. Learn more at the Global Privacy Control website.