This website (the “Site”) and any logos, designs, artworks, labels, symbols and any other details including
but not limited to those mentioned above are the sole property of PARAGON CAPITAL MANAGEMENT
SINGAPORE PTE. LTD. a company registered in Singapore, bearing UEN number 201726091H, and having
its registered address at 1 Wallich Street #25-03 | Guoco Tower | Singapore 078881, Singapore (the
The Company holds a Capital Markets Services (CMS) License under the Securities and Futures Act
(Chapter 289) of Singapore (the “SFA”) to conduct regulated activities in Dealing with Securities for
accredited and institutional investors (as defined pursuant to section 4A (Specified classes of investors) of
Your use of the Site, and of any information, content or services provided through the Site is entirely at
Your own risk. You understand that the Company does not guarantee or warrant the truth, accuracy,
adequacy, completeness or reasonableness of the information and content on the Site and that the same
is being provided for Your use at Your control.
“Applicable Law” refers to the laws, rules and regulations currently in force in Singapore that are
relevant to, and affecting, the provisions of this Agreement and to the Parties’ obligations
“Business Day” refers to working days in Singapore and essentially refers to days on which banks in
Singapore are operational or open for business.
“Product” refers to any capital market product that include securities, futures contracts, contracts
or arrangements for the purposes of foreign exchange trading, contracts or arrangements for the
purposes of leveraged foreign exchange trading, and such other products as the Monetary
Authority of Singapore (MAS) may prescribe as capital market products from time to time and set
out specifically under section 2 (Interpretation) of the SFA.
“User” or “You” refers to you, i.e. any individual or legal entity who seeks to use the Site and the
term “Your” shall be construed accordingly.
Any references to Clauses in these terms and conditions refers to clauses defined within the scope
of these terms and conditions.
Words that impart the singular shall include the plural and vice versa. Words that impart a gender
shall include every gender and references to persons shall include an individual, a company, a
corporation, a partnership or a firm.
References to “includes” or “including” or similar words or expressions shall mean “without
limitation”, i.e. including but not limited to.
To be able to use the Site, You must be over 18 years of age. In case You are under 18, but would
like to use the Site, You can only do so with the involvement of a parent or a guardian.
You must not misuse the Site. By misuse, it means that You shall not commit, partake or encourage
any sort of criminal offence by law, transmit or distribute any malware or virus including but not
limited to the Trojan horse, worm, logic bomb or post any other material onto the Site or the
Mobile App which is malicious, technologically harmful, in breach of confidence or in any way
offensive or obscene.
You must not hack into any aspect of the Site, corrupt data, cause annoyance to other users,
infringe upon any other person’s proprietary rights, send unsolicited advertising or promotional
material, or attempt to affect the performance or functionality of any computer facilities of or
accessed throughout the Site. Any breach of this provision would constitute a criminal offence
under Applicable Law. In the event of such a breach occurring, the Company reserves the right to
report the breach to the relevant law enforcement authorities and ensure appropriate legal action
You may not decompile, reverse engineer or otherwise attempt to discover the source code of any
of the Company’s content available on the Site or through a service except under specific
circumstances expressly permitted by law or in writing.
The content on the Site are the copyrighted works of either the Company or its content/ software
providers, and the Company reserves and retains all rights in the content. Use of the Company
content available on the Site may be governed by the terms and conditions of an accompanying
end user license agreement.
5. COMPANY DISCLAIMERS
All contents contained on the Site are provided for informational purposes only. You further
acknowledge that nothing contained on the Site or made available through the Site constitutes
investment, legal, tax or other advice, nor is it to be relied upon in making any investment or other
decisions. You should seek professional advice prior to making any investment decisions.
The Company, to the fullest extent permissible by law, disclaims all liability for any errors in, or
omissions from, information or content posted on the Site. No warranty of any kind, whether
implied or express, or statutory (including but not limited to, warranties of satisfactory quality,
merchantability, title, fitness for a particular purpose, compatibility, non-infringement of third
party intellectual property rights, security or accuracy) is given in connection with the information
and content of the Site.
You acknowledge and agree that the Company does not guarantee, uninterrupted and error free
usage of the Site at all times. Further, the Company does not guarantee that all defects on the Site
will be cured or that the Site is free from any computer virus or malicious code.
The Company reserves the right to change, modify, suspend or discontinue the whole or any
portion of the Product or the Site at any time. The Company may also impose limits on certain
features or restrict your access to parts of or the entire Site without notice or liability.
You agree that the Company has the right, in its sole discretion, and without providing any notice,
to either restrict, suspend or terminate Your account and/or restrict Your access to any part of the
Site without assigning any reason.
The Company may provide links to other websites and applications that are owned or operated by
third parties (“Linked Sites”) that may be of relevance and interest to users. You agree that the
Company has no control over the content of those Linked Sites, and is not responsible for any form
of damage or loss that You may incur from viewing or browsing or using the Linked Sites or from
the content on those Linked Sites. These include any damages You may incur through virus,
malware, worms, errors or damaging material that may be present or embedded into such Linked
Sites. Any Linked Sites featured on the Site does not constitute the Company’s endorsement,
recommendation or verification of the Linked Sites’ content. The existence of such links shall not
constitute an endorsement of, or representation or warranty by the Company regarding such
websites, the contents of the websites, the products or services of the websites or the operators of
privacy policies of those sites, and shall be at Your own risk. The Company disclaims responsibility
for the privacy policies and customer information practices of third-party internet websites
hyperlinked from our Site.
Under no circumstances shall it be construed that, in case of Your access to and use of systems
(including messaging systems), services, content, materials, products, applications or programmes
of any third party (“Third Party Systems”), the Company is a party to any transaction, if any,
between You and such third party or that the Company endorses, sponsors, certifies, or is involved
in the provision of such Third-Party Systems accessible through the Site, the Company shall not be
liable in any way for Your access to and use of the systems or for any products obtained and/or
purchased from or services rendered by any such third party, and You agree that the same shall be
Your responsibility or that of the relevant third party.
You acknowledge and agree that You will be solely responsible for any access to or use of Third
Party Systems through the Site. If You access or use any Third-Party Systems through the Site , You
must comply with the relevant terms and conditions for the access or the use of such Third Party
Systems and be responsible for the registration and use of any user names or passwords required
to connect to any Third Party Systems. In particular, should access to and use of Third Party
Systems through the Site be prohibited (whether in full or in part) by such third-party terms and
conditions, please discontinue any such access and use as soon as possible upon becoming aware
of or receiving notice of such prohibition from the relevant third party.
6. LIMITATION OF LIABILITY
The Company, will not, in any circumstances, be liable for any loss or damages whatsoever,
including any direct, indirect, special, incidental or consequential damages, loss of profits or lost
opportunity, arising out of (i) Your use of the Site; or (ii) Your reliance on any information or
content or services provided on the Site; or (iii) any errors in, or omissions from, the Site
information and content; or (iv) Your reliance on any results obtained after entering the
calibrations on the Site.
You understand and agree that the Company is simply presenting information on the Site for You
to use as You see fit. You also understand that the results that You see depend on the calibrations
entered and that You are solely responsible for the calibrations inputted. You agree that the
results shown are as a direct consequence of the calibrations entered by You and that the
Company bears no responsibility for the results produced, or shown as a result of the calibrations
You have chosen to enter.
7. TERMS AND CONDITIONS OF USE REGISTRATION
By using the Site, You agree, in some instances, to provide the Company with certain personal
data, billing data and payment data (“Registration Details”). You understand and agree that the
Company will first verify and confirm these details prior to allowing You to register on and use the
Site. You also represent and warrant that You will not use the Platforms in a way that violates any
laws or regulations. You understand that the application (if applicable) provided on the Site is for
your understanding and use as You see fit based on details entered by You.
You understand that the results that are displayed are directly related to the calibrations that You
have entered without any input or guidance or suggestions from the Company and that You bear
the sole responsibility for the results displayed.
You represent and warrant that all information You provide when establishing Your account, and
when You access, view and purchase the Product, is and will remain up-to-date, complete and
You agree and warrant that You will not disclose (wilfully, negligently or otherwise) credentials of
your password to any third party or otherwise allow any third party to use Your password or Your
access to Your account. If You have reason to believe that a third party has gained access to Your
account, You must immediately notify the Company. The Company is not responsible for any losses
due to stolen or hacked passwords that are caused by or result from your negligence.
8. PROTECTION OF PERSONAL DATA AND INFORMATION
In strict accordance with the provisions of the Personal Data Protection Act, 2012 (the “PDPA”) and
all other applicable laws, personal data and information (“Personal Information”) collected by the
Company via the Site will be used solely in connection with the Company’s business. The Company
is committed to protecting personal information collected by it and will not share such information
with any third party or for any business or marketing purposes to the extent required by any law or
For a complete understanding on how Your Personal Information is being protected, please refer
Personal Information the Company collects from You, or that You provide with it, will be processed
by the Company. It also contains important information about Your rights in relation to Your
Personal Information and how to exercise them. Please read it carefully to understand the
Company’s practices regarding Personal Information and how the Company will treat it.
9. AGREEING TO THE TERMS AND CONDITIONS AND VARIATION
You sign up on the Site on behalf of a company or other entity, You represent and warrant that You
The Company reserves the right to amend these terms and conditions at any time. All
amendments to these terms and conditions will be posted on the Site. Your continued use of the
Site will be deemed to constitute acceptance of the new terms and conditions. If You do not agree
to use the amended Site, You have the right to cease using the services.
In the event that any of these provisions are found to be or become unlawful, invalid or otherwise
of Use shall continue in force as if such unlawful, invalid or unenforceable provision was severed
No failure or delay by the Company or You in exercising any right under these terms and conditions
shall operate as a waiver of such right or extend to or affect any other or subsequent event or
impair any rights or remedies in respect of it or in any way modify or diminish the Company’s or
Your rights under these terms and conditions. It shall not constitute a bar to the exercise of
enforcement at any subsequent time or times. Waiver of any right arising from a reach of non-
and signing by the party granting the waiver.
12. NO SOLICITATION OR RECOMMENDATION
The information contained on the Site have been prepared for informational purposes only
without regard to any particular user’s investment objectives, financial situation, or means, and the
Company is not soliciting any action based upon it. The information contained in or provided
through the Site is not to be construed as a promotion, recommendation; or an offer to buy or sell
any security; or the solicitation of an offer to buy or sell any Product; or to participate in any
particular trading strategy in any jurisdiction in which such an offer or solicitation, or trading
strategy would be illegal under the securities laws of such jurisdiction; or as an offer of services or
participation. Certain transactions, including (but not limited to) those involving futures, options,
and high-yield securities, with or without the use of leverage, give rise to substantial risk and are
not suitable for all investors. Although such information may be considered by the Company to be
reliable, the Company has not verified this information and does not represent that any such
information is accurate, current, or complete. No reliance may be placed for any purpose on the
information provided in this presentation or the accuracy or completeness thereof and no
responsibility can be accepted by Company to anyone for any action taken on the basis of such
Important information about the Products is contained in its respective information memorandum,
offering circular, prospectus (the “Referred Document”), which are available upon request from
the Company. Accordingly, the information contained herein shall not be construed as a
prospectus, notice, circular, material, advertisement, publication or other document used to make
an offer of securities, and includes any document deemed to be a prospectus under Section 257
(Document containing offer of securities for sale deemed prospectus) of the SFA. In the case of any
inconsistency between the terms in the Site and the Referred Document, the terms of the Referred
Document shall take precedence over the terms in this Site.
For the avoidance of doubt, this Site has not been prepared for delivery to and review by persons
to whom any offer of the Product is made to assist such person to make an investment decision.
This Site and the information contained herein shall not constitute part of the Referred Document.
The fact that the Company has made the content available to You through the Site is neither a
recommendation that You enter into a particular transaction nor a representation that any Product
described on the Site is suitable or appropriate for You. The transactions and investments
described in the Site involve significant risks, and You should not enter into any transactions unless
You have fully understood all such risks and have independently determined that such transactions
and investments are appropriate for You. Any discussion of the risks contained herein with respect
to any transaction or investment should not be considered to be a disclosure of all risks or
complete discussion of the risks which are mentioned. You should neither construe any of the
information contained herein as business, financial, investment, hedging, trading, legal, regulatory,
tax or accounting advice nor make the Site or the information contained therein the primary basis
for any investment decisions made by or on behalf of You, your accountants, or your managed or
fiduciary accounts, and You may want to consult your business advisor, attorney, and tax and
accounting advisors concerning any contemplated transactions and investments.
Any investment in the Product is not deposits in, obligations of, or guaranteed or insured by the
Company, and is subject to investment risks, including the possible loss of the principal amount
invested. Values of interests in the Product and income therefrom may fall or rise. Past
performance or any prediction, projection or forecast is not indicative of future or likely
performance. If You are considering making an investment, You are advised to obtain Your own
independent professional advice and to carefully consider all relevant risk factors. You may wish to
speak to any of the Company’s personnel first regarding Your suitability before making a
commitment to purchase any Product with the Company. In the event You choose not to do so,
You should consider whether the Product is suitable for You. Please contact the Company for more
information on how to subscribe the Product.
The Site are not directed at or intended for distribution to any person (or entity) who is a citizen or
resident of (or located or established in) any jurisdiction where the use of the Site or the offering of
the Products would be contrary to applicable law or regulation or would subject the Company to
any registration or licensing requirement in such jurisdiction. Persons who wish to subscribe to the
Products are required by the Company to inform themselves about and to observe any legal or
regulatory restrictions which may affect their eligibility to subscribe to the Products. Professional
advice should be sought from a financial or other professional advisor regarding the suitability of
any transactions and/or investments in the Products.
13. THIRD PARTY RIGHTS
No person who is not a party to these terms and conditions shall acquire any rights under the
Contracts (Rights of Third Parties) Act, Chapter 53B of Singapore or similar legislation in any
person has relied on any such term or has indicated to any party to these terms and conditions its
assent to any such term. For the avoidance of doubt, nothing in this provision shall affect the rights
14. GOVERNING LAW
These terms and conditions and all obligations arising from or connected therein, shall be
governed and construed in accordance with the laws of Singapore. Both You, and the
Company, agree hereby to submit to the non-exclusive jurisdiction of Singapore courts in
relation to any disagreements or disputes arising out of these terms and conditions and any
transactions between the parties governed by the terms herein. All dealings, correspondence
and contacts between us shall be in English.