Privacy Policy - Alpha Waitlist

1. Introduction

This Privacy Policy describes how Helix Alpha Trading Pte Ltd (UEN 202617663Z), a company incorporated in Singapore with its registered office at 165B Telok Ayer Street, Singapore 068617 ("we," "us," "our," or the "Data Controller"), collects, uses, stores, and discloses your personal data when you register for the waitlist available at https://www.tradealpha.app/ (the "Site"). This Privacy Policy is provided in accordance with the Singapore Personal Data Protection Act 2012 (as amended) ("PDPA"), and applies to all personal data collected in connection with your waitlist registration.

By registering for the waitlist, you acknowledge that you have read and understood this Privacy Policy. Where consent is the lawful basis for processing under the PDPA, you expressly consent to the collection, use, processing, storage, and disclosure of your personal data as described herein. You acknowledge that you may withdraw your consent at any time by contacting us at [email protected], though this may affect our ability to provide services to you.

Registration for the waitlist does not constitute an offer to sell or solicitation to buy any security, commodity, or other investment product, and does not guarantee access to any products or services.

2. Information We Collect

We collect the following categories of personal data:

(a) Information you provide directly: name, email address, geographic location information, and any other information you choose to provide when registering for the waitlist;

(b) Automatically collected technical information: IP address, browser type, device information, and usage data collected through cookies and similar technologies when you access the Site (you have the right to refuse cookies through your browser settings, though this may affect Site functionality); and

(c) Derived geolocation data: geographic location information derived from your IP address to verify compliance with geographic access restrictions.

The legal basis for processing this data is: (i) your consent for marketing communications and waitlist registration; (ii) our legitimate interests in operating the Site, preventing fraud, and ensuring compliance with geographic restrictions; and (iii) compliance with legal obligations under applicable law.

You represent and warrant that all information you provide is accurate, current, and complete, and you agree to update your information if it changes. You can update your information by contacting us at [email protected].

3. Use of Your Information

We use your personal data for the following purposes, each with its corresponding legal basis under the PDPA:

(a) to process and manage your waitlist registration (legal basis: legitimate interests/your consent);

(b) to communicate with you about the waitlist, the Platform, and related services (legal basis: legitimate interests);

(c) to send you marketing and promotional communications regarding the Platform and related services, subject to your right to opt out at any time (legal basis: your express consent);

(d) to verify your eligibility and geographic location in connection with access to the Platform (legal basis: legitimate interests in compliance with regulatory requirements and fraud prevention);

(e) to comply with applicable laws and regulations, including the PDPA (legal basis: legal obligation);

(f) to enforce our Terms of Service and protect our legal rights (legal basis: legitimate interests); and

(g) to improve and enhance the Site and our services (legal basis: legitimate interests).

Where we rely on legitimate interests as a legal basis, you have the right to object to such processing as set forth in Section 9.

4. Marketing Communications

By registering for the waitlist, you expressly consent to receive marketing and promotional communications from us regarding the Platform and related services, in accordance with applicable law including the PDPA. This consent is optional and separate from your waitlist registration. You may opt out of such communications at any time by following the unsubscribe instructions in any email we send or by contacting us at [email protected]. We will process your opt-out request promptly and in any event within ten (10) business days. Opting out of marketing communications will not affect your waitlist registration status.

5. Disclosure of Your Information

We may share your personal data with third-party service providers who assist us in operating the Site and providing services related to the waitlist and the Platform. Such service providers are contractually bound to: (i) process personal data only on our documented instructions; (ii) implement appropriate technical and organizational security measures as required by the PDPA; (iii) maintain confidentiality; (iv) assist us in responding to data subject rights requests; (v) not engage sub-processors without our prior written authorization; (vi) ensure that persons authorized to process personal data are subject to confidentiality obligations; and (vii) delete or return personal data upon termination of services, unless legally required to retain it.

We remain responsible for our service providers' compliance with data protection obligations. We will not sell your personal information to third parties.

We may also disclose your personal data:

• (a) to comply with applicable laws, regulations, or legal processes;
• (b) to respond to lawful requests from governmental authorities;
• (c) to protect our rights, privacy, safety, or property, or that of our users or the public;
• (d) in connection with a merger, acquisition, corporate reorganization, sale of assets, or similar transaction, provided that the acquiring entity agrees to assume our obligations under this Privacy Policy and comply with the PDPA, and provided further that we will notify you in advance of any such transaction that results in a change of control and provide you with the opportunity to object or withdraw consent where applicable; and
• (e) with your consent or at your direction.

6. Data Retention

We will retain your personal data in accordance with the following retention periods:

(a) Waitlist registration data: until you are approved for Platform access, you request removal, or after a period of inactivity, whichever occurs first;

(b) Marketing communications data: until you withdraw consent or after your last interaction with our communications;

(c) Technical and usage data: for a limited period from collection;

(d) Data retained for legal compliance: for such period as required by applicable law, regulation, or legal process.

If you are not approved for Platform access or if you request removal from the waitlist, we will delete or anonymize your information within thirty (30) days after such determination or request, unless legally required to retain it longer. You may request deletion of your data by contacting us at [email protected], subject to applicable legal exceptions under the PDPA, including our legal obligations to retain certain information.

7. Security

We will implement commercially reasonable security measures appropriate to the sensitivity of the information to protect your personal data from unauthorized access, use, or disclosure. However, you acknowledge and agree that no security measures are absolute or can guarantee complete security, and we cannot guarantee that your personal data will not be accessed, disclosed, altered, or destroyed. You agree to maintain confidentiality of any access credentials and to notify us immediately upon becoming aware of any unauthorized access or security incident.

8. Breach Notification

In the event of a security breach affecting your personal data that we are legally required to report under the Singapore Personal Data Protection Act 2012 or other applicable law, we shall provide notice to you without unreasonable delay and in accordance with applicable breach notification laws. Such notice shall be provided to the email address you provided to us. Our obligation to provide notice is limited to breaches that trigger legal notification requirements under applicable law.

9. Your Data Protection Rights

You have certain rights regarding your personal data under the Singapore Personal Data Protection Act 2012 and other applicable data protection laws. These rights include:

• (a) the right to access your personal data and obtain a copy of it;
• (b) the right to request correction of inaccurate or incomplete personal data;
• (c) the right to request deletion of your personal data, subject to certain exceptions;
• (d) the right to restrict processing of your personal data in certain circumstances;
• (e) the right to object to processing of your personal data for certain purposes; and
• (f) the right to data portability, where applicable.

You may request to exercise any of these rights by sending a written request to [email protected]. We will respond to verified requests within thirty (30) days or such other timeframe as required by applicable law, subject to applicable legal requirements and exceptions. You also have the right to lodge a complaint with the Personal Data Protection Commission of Singapore ("PDPC") if you believe your data protection rights have been violated.

10. International Data Transfers

Your personal data may be transferred to, stored, and processed in jurisdictions outside of Singapore. By registering for the waitlist, you consent to such transfers, provided that we will take appropriate measures to ensure that your personal data remains protected in accordance with this Privacy Policy and applicable data protection laws.

11. Electronic Communications

By registering for the waitlist, you affirmatively consent to receive all communications, agreements, documents, receipts, notices, and disclosures electronically. We may provide such communications to you by posting them on the Site, emailing them to the email address you provide during registration, or through any other electronic means. To access and retain electronic communications, you will need a device with internet access, a current web browser with cookies enabled, a valid email address, and sufficient storage space to save communications or a printer to print them. You may withdraw your consent to receive electronic communications at any time by contacting us at [email protected]; however, if you withdraw your consent, we may terminate your waitlist registration.

12. Children's Privacy

The Site and waitlist registration are not intended for individuals under 18 years of age (or the age of majority in your jurisdiction, if greater than 18 years of age). We do not knowingly collect personal data from individuals under such age. If we become aware that we have collected personal data from an individual under such age, we will take steps to delete such information.

13. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. Changes will be effective upon posting to the Site. Your continued use of the Site following any changes constitutes acceptance of the modified Privacy Policy. We encourage you to review this Privacy Policy periodically for any updates.

14. Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of Singapore, without regard to its conflict of law principles, and in compliance with the Singapore Personal Data Protection Act 2012.