Prime Trade Management Services Pte Ltd (UEN 202020771G) ("Prime TMS", "we", "us", "our") operates TradeAlly and the Prime TMS corporate website (collectively, the "Services"). This Privacy Policy explains how we collect, use, disclose, and protect personal data in compliance with the Singapore Personal Data Protection Act 2012 (as amended) ("PDPA") and, where applicable to users in the European Economic Area or United Kingdom, the General Data Protection Regulation ("GDPR").
We collect: (a) Account and Contact Data — name, business email, company name, phone number, billing address; (b) Usage Data — screening queries, search history, feature usage, log files, IP address, device/browser type; (c) Payment Data — processed by Stripe, Inc.; we retain only transaction references, not full card details; (d) Cookies and Tracking Data — as set out in our Cookie Policy; (e) Screening Input Data — HS codes, entity names, and trade data voluntarily submitted by users for screening against Restricted Party, sanctions, PEP, criminal watchlist, and adverse media databases.
We process personal data to: provide and maintain the Services; process subscriptions and payments; deliver screening results; communicate service updates and security notices; improve product functionality; comply with legal and regulatory obligations; and prevent fraud or misuse. Under PDPA, our legal basis includes consent, contractual necessity, and legitimate business purposes. Under GDPR, our legal bases include Article 6(1)(b) contract performance, 6(1)(c) legal obligation, and 6(1)(f) legitimate interests.
We share personal data only as necessary with: Stripe (payment processing); cloud hosting and infrastructure providers (Railway and associated hosting/database providers); analytics providers (aggregated, where used); and regulators or law enforcement where legally compelled. We do not sell personal data to third parties.
Personal data is retained only as long as necessary for the purposes described above, for the duration of an active subscription plus a reasonable period thereafter for legal, accounting, and dispute-resolution purposes (generally up to 7 years for financial records, per Singapore statutory requirements), after which data is securely deleted or anonymised.
Subject to PDPA and, where applicable, GDPR, you may request: access to your personal data; correction of inaccurate data; withdrawal of consent; deletion of your data (subject to legal retention obligations); and data portability. Requests may be sent to our Data Protection Officer (see 1.9).
As our Services are hosted on cloud infrastructure that may process data outside Singapore, we ensure any overseas recipient of personal data is bound by legally enforceable obligations providing a standard of protection comparable to the PDPA, consistent with section 26 of the PDPA and, where applicable, GDPR Standard Contractual Clauses.
The Services are intended for business and professional use by persons aged 18 and above. We do not knowingly collect personal data from children. Any such data discovered will be deleted promptly.
For privacy enquiries or to exercise your rights, contact our Data Protection Officer: Murray Cooper, mcooper@primetmsglobal.com, +65 9715 2288, 531A Upper Cross Street #04-95, Hong Lim Complex, Singapore 051531.
We may update this Privacy Policy from time to time. Material changes will be notified via the Services or by email. Continued use of the Services after changes take effect constitutes acceptance.