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Terms of Use

These Terms of Use (“Terms”) govern access to and use of the Rayft website at (“Site”) and any related mobile application (“Mobile App”) by all third parties granted access (“Users”), including members and contributor (analyst). All rights and restrictions conferred under these Terms which relate to access or use of the Site or Content apply equally to any access or use of the Site or Content through any Mobile App. Please read these Terms carefully and contact us if you have any questions. By proceeding to access and use the Site and/or Mobile App, you are agreeing to be bound by these Terms.

1. Using Rayft

You may access and use the Site and/or Mobile App if you are a member, contributor (analyst) or other approved User, and have entered into a relevant binding agreement to this effect with Rayft (“User Agreement”). Users will be set up with a User Account (see further below). Your use of the Site and/or Mobile App will be governed by these Terms, the terms of the relevant User Agreement, and any applicable laws and regulations. 


Subject to these Terms and any provisions contained in the applicable User Agreement, Rayft grants Users a limited, non-exclusive, non-transferable and revocable licence to access and use the Site (including through any Mobile App) for the designated purposes.

2. User Content

Rayft allows you to upload and post Content to the Site. Content is anything that you post or otherwise make available on the Site (directly and/or through any Mobile App). Users retain all rights in their Content and remain solely responsible for any Content they post.

By submitting Content, you grant Rayft and other Users a non-exclusive, revocable, royalty free, worldwide licence to read and use the Content you post in accordance with the rights and obligations contained in the applicable User Agreements. Nothing in these Terms restricts any other legal rights Rayft may have in relation to the Content, for example those rights granted by the User Agreements.

The User Agreements contain important provisions regarding the Content which Users post on the Site, including, amongst others, requirements that Content:

  • must not be inaccurate (where it contains facts) and must be genuinely held (where it contains opinions);

  • must comply with applicable law and regulations in Singapore and in any country from which they are posted;

  • must not contain non-public information;

  • must not be threatening or defamatory of any person;

  • must not contain any material which is obscene, offensive, hateful, discriminatory, inflammatory or contain any prohibited material as described in the Singapore Media Development Authority’s Internet Code of Conduct, as published from time to time; and

  • must not contain information that is confidential or proprietary to another party without prior consent.

  • In addition, you agree that you will not otherwise use the Site (directly and/or through any Mobile App) in any way that:

constitutes unauthorised or unsolicited advertising, junk or bulk email (“spamming”); or is unlawful, threatening, abusive, harassing, defamatory, deceptive, fraudulent, tortious, obscene, vulgar, pornographic, offensive, profane or is otherwise inappropriate as determined by us in our sole discretion.

Rayft does not guarantee that any Content posted will be made available on the Site, either directly or through any Mobile App. We reserve the right to, but do not have any obligation to, remove or modify or restrict access to Content for any reason, including Content that is in breach of these Terms, the User Agreements or applicable law.

3. User registration and Account Security

You will be required to open a User Account to access the Site, either directly or through the Mobile App. You must not disclose your password or permit or authorise any other person to use your login name or password for any purpose whatsoever.

Any access to or use of the Site using your login name and password may be treated as access or use by you, notwithstanding it may have been by a third party without your knowledge or authority.

If you become aware that a third party has acquired knowledge of or has used your password to access or use the Site (whether with or without your knowledge and consent), you must immediately notify Rayft and provide relevant details, and change your password.

4. Rayft Site Security

Rayft uses best commercial efforts to protect the security of the Site, Mobile App, Content and User Accounts. However, Rayft cannot guarantee that unauthorised third parties will not defeat security measures. You must adhere to the User Account security measures outlined above and notify Rayft immediately of any compromise or unauthorised use of your account.

5. Termination and Suspension of Accounts

Rayft may terminate or suspend your use of the Site and/or Mobile App, with or without cause, in accordance with the applicable User Agreement.

6. General Disclaimer

The Site and Content on the Site are provided for informational purposes only. Reliance should not be placed on the views and information expressed on the Site when making individual investment or other strategic decisions. Views expressed in third party Content are those of the authors and do not necessarily represent Rayft’s views.

The Site, Mobile App and Content are provided on an “as is” and “as available” basis without warranty of any kind, whether express or implied.

Rayft specifically disclaims any and all warranties and conditions of merchantability, fitness for a particular purpose, and non-infringement, and any warranties arising out of course of dealing or usage of trade.

Rayft further does not warrant that the Site and/or Mobile App or the functions contained in the Site and/or Mobile App will be secure, available, uninterrupted or error-free, that defects will be corrected or that the Site will be free of viruses or other harmful components or that the results of using the Site and/or Mobile App will meet your requirements.

Rayft takes no responsibility and assumes no liability for any Content that you or any other User posts or transmits using the Site and/or Mobile App. You understand and agree that you may be exposed to Content that is inaccurate, objectionable, or otherwise unsuited to your purpose.

Under Singapore financial law and regulation, Rayft is an exempt information service provider. For the avoidance of doubt, Rayft is not a broker, dealer, investment or financial adviser under Singapore law or securities laws of other jurisdictions. Rayft does not advise individuals or entities as to the advisability of investing in, purchasing, or selling securities or other financial products or services.

This Site and/or Mobile App and the Content published on it is not intended to provide financial, investment, legal, accounting or tax advice, or any other professional advice, and nothing on this Site and/or Mobile App, including any Content, should be construed as an offer to sell, a solicitation of an offer to buy, or a recommendation for any security. Users should at all times consult a qualified expert or professional adviser to obtain advice and independent verification of the information and data contained in any Content before acting on it.

7. Indemnification

In addition to any specific terms imposed under your User Agreements, Users agree to indemnify Rayft, its affiliates, officers and employees, against any loss, damage, claims or expenses (including reasonable legal fees) that arise from or relate to:

  • your Content;
  • your use or misuse of, or access to, the Site and/or Mobile App;

  • your breach of these Terms or your User Agreement; and/or

  • infringement by you (or by a third party using your Account or identity) of any intellectual property or other rights of any person or entity.

8. Liability Limitation


9. General Terms

We may revise these Terms from time to time and the most current version will always be posted on the Site and/or via a link on the Mobile App. If a revision, in our sole discretion, is material we will notify you. By continuing to access or use the Site and/or Mobile App after the revisions become effective, you are agreeing to be bound by the revised Terms. If you do not agree to the revised Terms, you must stop using the Site and/or Mobile App. Where rights and obligations are dealt with under both these Terms and the User Agreement, then we agree that those rights and obligations may only be changed in accordance with the variation rights under the User Agreement, and further that the terms in the User Agreement are to prevail in the event of any inconsistency.

These Terms are governed by Singapore Law. You agree that any dispute arising from or relating to the subject matter of these Terms shall be governed by the exclusive jurisdiction and venue of the courts of Singapore.

Privacy policy

This Privacy Policy has been developed in line with the Personal Data Protection Act 2012 (Singapore) (“PDPA”) and other data protection laws from relevant jurisdictions, including the General Data Protection Regulation (“GDPR”) which comes into effect in the European Union on 25 May 2018.

This Privacy Policy describes in detail how Rayft and its group companies may collect, use, disclose, process and manage your personal data. By visiting or using the Site or Mobile App, or by engaging with Rayft or its group companies, you are hereby accepting the terms of this Privacy Policy.

This version of the Privacy Policy is current as of 16 May 2018

1. Types of Personal Data Rayft collect

“Personal data” is any data that can be used to identify a natural person or individual. Examples of personal data that we may collect from you, either directly when you engage with Smartkarma or its group companies, or otherwise through your use of the Site or Mobile App, include:

  • professional and personal details such as your name, gender, contact details, contact preferences and IP address;

  • details of transactions or interactions you carry out through our Site and/or Mobile App;

  • details of your visits to our site (including, but not limited to, traffic data, location data, weblogs and other communication data) and the resources and links that you access; and

  • records in connection with service provision to Users including records of correspondence and records of use of the Site and other related services, account details, records of agreements and other transactions, notes from interactions and information used for monitoring and regulatory compliance.

2. How does Rayft collect Personal Data

We collect, process and retain personal information from you when you enter into a User Agreement or register for an account with us, and each time you navigate to the Site or Mobile App and interact or transact with us.

To capture user and usage data, individual preferences and browsing behaviour, we use cookies, web beacons and similar technologies to collect information about your visit to the Site or Mobile App, such as the pages you view, content you read, links you click and other actions you take on the Site or Mobile App.

You may set up your web browser to block or disable cookies which will in turn disable the monitoring of your visit. You may also remove cookies stored from your computer or mobile device. However, if you do block or disable cookies, you may not be able to use or receive certain personalised features and functions of the Site or Mobile App.

Please also note that the Site may contain links to other websites which are not operated or maintained by Rayft. When visiting these third party websites, you should read their privacy and data protection policies which will solely apply to your use of those third party websites.

3. How Rayft use Personal Data

Rayft will always process your personal data for a specific purpose, and process only the personal data that is relevant for achieving that purpose.


Depending on our relationship with you and the products and services that we provide to you, we may process your personal data for the following business purposes and associated compatible purposes:

  • Account opening and on-boarding;

  • Understanding client needs and offering products and services;

  • Providing products and services;

  • Managing our relationships with Users and connected parties;

  • Communicating with Users;

  • Carrying out operational and administrative functions;

  • Helping us to improve our products and services;

  • Managing and conducting our business;

  • Monitoring and assessing risk, conducting audits and enforcing our rights;

  • Marketing our products and services to Users; and

  • Meeting our regulatory and compliance obligations.

4. Disclosure, Sharing and Transfer of Personal Data

To support or enhance the delivery and performance of the above business purposes, Rayft uses the services of selected, authorised third party processors with whom Rayft has data processing agreements in place to ensure that all such disclosure and use is in compliance with relevant privacy laws, including where applicable the GDPR.

Rayft does not sell personal data to any third parties under any circumstances. Rayft shall also remain fully compliant with any contractual duty or obligation of confidentiality imposed on it under the applicable User Agreements or Terms of Use that govern our relationship with our Users and/or any applicable law.

Data sharing outlined in this Privacy Policy may involve the transfer of personal data to any country in which Rayft or a group company conducts business or has a service provider, or to other countries for law enforcement purposes. In doing so, we will comply with the PDPA and other applicable data protection and privacy laws, including where applicable the GDPR and ensure that appropriate safeguards are in place to protect your personal data. 

5. Personal Data Retention

Rayft will retain your personal data for the period of time required for the business purposes for which it was collected or to comply with legal, regulatory and internal compliance requirements.

6. Updates of Privacy Policy

The above information may change from time to time resulting in an update to this Privacy Policy – for example, the categories of personal data that Rayft collects, the purposes for which it is used and the ways in which it is shared may change. We will make the updated policy available here and notify our Users of material updates in writing. All communications, transactions and dealings with Rayft will be subject to the latest version of this Privacy Policy in force from time to time.

Privacy policy
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