Antalpha AI Website (antalpha.ai)

PRIVACY POLICY AND COOKIE POLICY

Last updated: 7 September 2023

A. PRIVACY POLICY

1. WHO WE ARE

This data privacy policy (the “Privacy Notice”) and the cookie policy at the bottom (the “Cookie Policy”) (together, “Policies”) applies to all personal data collection and processing activities carried out by Antalpha entities (including Antalpha Digital Pte Ltd (SG) and PT Antalpha Technologies Indonesia) and its group of companies (together, “Antalpha”). In this notice, references to “we”, “us” or “our” are references to Antalpha. We respect individuals’ rights to privacy and to the protection of personal data. The purpose of this Privacy Notice is to explain how we collect and use personal data in connection with our business.

For the purposes of the Policies, “personal data” means data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which the organization has or is likely to have access.

We may update our Policies from time to time. When we do we will communicate any changes to you and publish the updated Policies on our website. We would encourage you to visit our website regularly to stay informed of the purposes for which we process your information and your rights to control how we process it.

2. THE INFORMATION WE PROCESS

We may collect, process and use various categories of personal data at the start of, and for the duration of, your relationship with us. We will limit the collection and processing of information to information necessary to achieve one or more legitimate purposes set out at Schedule B – Purposes of Processing).

Personal data may include:

A. basic personal data, including name and address, and contact details;

B. financial information, including account and transactional information and history;

C. any photographs or texts that you share with us for purposes of us providing goods and services to you which allude to or reveal any personal data;

D. visual images and personal appearance (such as photos); and

E. online profile and social media information and activity, based on your interaction with us and our websites and applications, including for example your login information, Internet Protocol (IP) address, smart device information, location coordinates, online and mobile app security authentication, mobile phone network information, searches, site visits and spending patterns.

3. HOW WE OBTAIN INFORMATION

Your information is made up of all the personal data we collect and hold about you and your activity on our website. It may include:

A. information you give to us;

B. information that we receive from third parties, if any – including other Antalpha group companies, third parties who provide services to you or us, credit reference, fraud prevention or government agencies,

C. information that we learn about you through our relationship with you and the way you operate your accounts and/or services;

D. information that we gather from the technology which you use to access our services (for example location data from your mobile phone, or an IP address or telephone number) and how you use it (for example pattern recognition); and

F. information that we gather from publicly available sources, such as the press, the electoral register, company registers and online search engines.

4. YOUR RIGHTS

We want to make sure you are aware of your rights in relation to the personal data we process about you – as described in Schedule A. Please note that Antalpha will only comply with such requests to the extent it is legally obligated to. Please note that in some cases, if you do not agree to the way we process your information, it may not be possible for us to continue to operate your account and/or provide certain products and services.

5. CHANGES TO THE WAY WE USE YOUR INFORMATION

From time to time we may change the way we use your information. Where we believe you may not reasonably expect such a change we will notify you and will allow a period of at least 30 days for you to raise any objections before the change is made. However, please note that in some cases, if you do not agree to such changes it may not be possible for us to continue to provide certain products and services to you.

6. HOW WE MAY USE AND SHARE YOUR INFORMATION WITH OTHER ANTALPHA GROUP COMPANIES

We will only use and share your information where it is necessary for us to lawfully carry out our business activities. We have described the purposes for which your information may be used in detail in a table in Schedule B – Purposes of Processing.

7. SHARING WITH THIRD PARTIES

We may from time to time share and disclose your personal data and other data to third parties, some of whom may be located outside your home country. The circumstances under which such sharing and disclosure will take place may include without limitation the following:

A. where we have your permission;

B. where required to provide your product(s) or service(s);

C. where we are required by law and by law enforcement agencies, judicial bodies, government entities, tax authorities or regulatory bodies around the world;

D. with third parties providing services to us that are ancillary to the product or service we are providing to you;

E. where required for a proposed sale, reorganisation, transfer, financial arrangement, asset disposal or other transaction relating to our business and/or assets held by our business;

G. in anonymised form as part of statistics or other aggregated data shared with third parties; or

H. where permitted by law, it is necessary for our legitimate interests or those of a third party, and it is not inconsistent with the purposes listed above.

8. TRANSFERRING INFORMATION OVERSEAS

You agree that your personal data may be sent and stored in a country that is not your home country or the country where you provided us with the personal data.

If your personal data in a particular country is sent outside that country, we will seek to ensure that your personal data is afforded a comparable level of protection as that provided by Antalpha and as required by the law of the first mentioned country.

9. COMMUNICATIONS ABOUT YOUR ACCOUNT

We will contact you with information relevant to the operation and maintenance of your Antalpha account (including updated information about how we process your personal data), by a variety of means including via, email, text message, and in-app notifications. If at any point in the future you change your contact details you should tell us promptly about those changes. We may monitor or record calls, emails, text messages or other communications in accordance with applicable laws for the purposes outlined in Schedule B – Purposes of Processing.

10. HOW LONG WE KEEP YOUR INFORMATION

By providing you with products or services, we create records containing your information, such as customer account records and activity and transaction records. Retention periods for records are determined based on the type of record, the nature of the activity, product or service, the country in which the relevant Antalpha company is located and the applicable local legal or regulatory requirements.

We (and other Antalpha group companies) normally keep customer account records for up to six years after your relationship with Antalpha ends. Retention periods may be changed from time to time (or waived where deemed low-risk) based on business or legal and regulatory requirements.

If there has been any transactional activity on your account, we will maintain your data until you request that we delete it, unless we are obligated to maintain such data to comply with our legal obligations. We may on exception retain your information for longer periods than those stated above, particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies or our regulators. This is intended to make sure that Antalpha will be able to produce records as evidence, if they’re needed.

We will endeavor to anonymise or aggregate your data if we intend to use it for analytical purposes or trend analysis.

Antalpha will use reasonable endeavours to maintain appropriate physical, electronic and organisational procedures to ensure that your personal data and other data is treated securely and in accordance with this Privacy Policy, and to protect such data against unauthorized access or unauthorized alteration, disclosure or destruction of data.

Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. Antalpha does not give any representation, warranty or undertaking that the personal data you provide to us will be secure at all times, and to the extent Antalpha has fulfilled its obligations under no circumstances shall Antalpha be responsible for any losses, damages, costs and expenses which you may suffer or incur arising from unauthorised access to or use of your personal data.

Schedule A – Your Rights

1. Access – You have a right to get access to the personal data we hold about you.

If you would like a copy of the personal data we hold about you, email us at support@antalpha.com ; For more information on how to get access to your information and the documents we need you to submit, please email support@antalpha.com . You will be required to complete a form outlining your request and will also need to provide proof of your identity (to ensure we are dealing with the account owner).

2. Rectification – You have a right to rectification of inaccurate personal data and to update incomplete personal data. If you believe that any of the information that we hold about you is inaccurate, you have a right to request that we restrict the processing of that information and to rectify the inaccurate personal data. Please note that if you request us to restrict processing your information, we may have to suspend the operation of your account and/or the products and services we provide to you. For more information on how to rectify your information and the documents we need you to submit, please email support@antalpha.com . You will be required to complete a form outlining your request and will also need to provide proof of your identity (to ensure we are dealing with the account owner).

3. Restriction – You have a right to request us to restrict the processing of your personal data. You may request us to restrict processing your personal data if you believe that:

A. any of the information that we hold about you is inaccurate;

B. we no longer need to process your information for the purposes for which it was provided, but you require the information to establish, exercise or defend legal claims; or

C. we are not using your information in a lawful manner.

Please note that if you request us to restrict processing your information, we may have to suspend the operation of your account and/or the products and services we provide to you. For more information on how to request a restriction of processing of your information and the documents we need you to submit, please email support@antalpha.com . You will be required to complete a form outlining your request and will also need to provide proof of your identity (to ensure we are dealing with the account owner).

4. Objection – You have a right to object to the processing of your personal data. You have a right to object to us processing your personal data (and to request us to restrict processing) for the purposes described in Section C of Schedule B – Purposes of Processing (below), unless we can demonstrate compelling and legitimate grounds for the processing, which may override your own interests, or where we need to process your information to investigate and protect us or others from legal claims. Depending on the circumstances, we may need to restrict or cease processing your personal data altogether or, where requested, delete your information. Please note that if you object to us processing your information, we may have to suspend the operation of your account and/or the products and services we provide to you.

5. Withdraw consent – You have a right to withdraw your consent. Where we rely on your permission to process your personal data, you have a right to withdraw your consent at any time. We will always make it clear where we need your permission to undertake specific processing activities.

Schedule B – Schedule of Purposes of Processing

We will only use and share your information where it is necessary for us to carry out our lawful business activities. Your information may be shared with and processed by other Antalpha group companies. We want to ensure that you fully understand how your information may be used. We have described the purposes for which your information may be used in detail below:

1. CONTRACTUAL NECESSITY

We may process your information where it is necessary to enter into a contract with you for the provision of our products or services or to perform our obligations under that contract. Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to operate your account and/or provide products and services to you. This may include processing to:

A. assess and process applications for products or services;

B. provide and administer those products and services throughout your relationship with Antalpha, including opening, setting up or closing your accounts or products; collecting and issuing all necessary documentation; executing your instructions; processing transactions, including transferring money between accounts; making payments to third parties; resolving any queries or discrepancies and administering any changes. Calls to our service centre and communications to our mobile and online helplines may be recorded and monitored for these purposes.

C. manage and maintain our relationships with you and for ongoing customer service. This may involve sharing your information with other Antalpha group companies to improve the availability of our services.

2. LEGAL OBLIGATION

When you apply for a product or service (and throughout your relationship with us), we are required by law to collect and process certain personal data about you. Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to operate your account and/or provide products and services to you. This may include processing to:

A. confirm your identity, including using biometric information and facial recognition technology and other identification procedures, for example fingerprint verification;

B. perform checks and monitor transactions and location data for the purpose of preventing and detecting crime and to comply with laws. This may require us to process information about criminal convictions and offences, to investigate and gather intelligence on suspected financial crimes, fraud and threats and to share data with law enforcement and regulatory bodies;

C. share data with police, law enforcement, tax authorities or other government and fraud prevention agencies where we have a legal obligation, including reporting suspicious activity and complying with production and court orders;

D. deliver mandatory communications to customers or communicating updates to product and service terms and conditions;

E. investigate and resolve complaints;

F. conduct investigations into breaches of conduct and corporate policies by our employees;

G. manage contentious regulatory matters, investigations and litigation;

H. perform assessments and analyse customer data for the purposes of managing, improving and fixing data quality;

I. provide assurance that Antalpha has effective processes to identify, manage, monitor and report the risks it is or might be exposed to;

J. investigate and report on incidents or emergencies on Antalpha’s properties and premises;

K. coordinate responses to business-disrupting incidents and to ensure facilities, systems and people are available to continue providing services; and

L. monitor dealings to prevent market abuse.

3. LEGITIMATE INTERESTS OF ANTALPHA

We may process your information where it is in our legitimate interests do so as an organization and without prejudicing your interests or fundamental rights and freedoms.

We may process your information in the day-to-day running of our business, to manage our business and financial affairs and to protect our customers, employees and property. It is in our interests to ensure that our processes and systems operate effectively and that we can continue operating as a business.

This may include processing your information to:

A. monitor, maintain and improve internal business processes, information and data, technology and communications solutions and services;

B. ensure business continuity and disaster recovery and responding to information technology and business incidents and emergencies;

C. ensure network and information security, including monitoring authorised users’ access to our information technology for the purpose of preventing cyber-attacks, unauthorised use of our communications systems and websites, prevention or detection of crime and protection of your personal data;

D. provide assurance on Antalpha’s material risks and reporting to internal management and supervisory authorities on whether Antalpha is managing them effectively;

E. perform general, financial and regulatory accounting and reporting;

F. protect our legal rights and interests; and

G. enable a sale, reorganisation, transfer or other transaction relating to our business.

It is in our interest as a business to ensure that we provide you with the most appropriate products and services and that we continually develop and improve as an organisation. This may require processing your information to enable us to:

A. identify new business opportunities and to develop enquiries and leads into applications or proposals for new business and to develop our relationship with you;

B. send you relevant marketing information (including details of other products or services provided by us or other Antalpha group companies which we believe may be of interest to you);

C. understand our customers’ actions, behaviour, preferences, expectations, feedback and financial history in order to improve our products and services, develop new products and services, and to improve the relevance of offers of products and services by Antalpha group companies;

D. monitor the performance and effectiveness of products and services;

E. assess the quality of our customer services and to provide staff training. Calls to our Customer Support teams and communications to our mobile and online helplines may be recorded and monitored for these purposes;

F. perform analysis on customer complaints for the purposes of preventing errors and process failures and rectifying negative impacts on customers;

G. compensate customers for loss, inconvenience or distress as a result of services, process or regulatory failures;

H. identify our customers’ use of third-party products and services in order to facilitate the uses of customer information detailed above; and

I. combine your information with third-party data, such as economic data in order to understand customers’ needs better and improve our services.

We may perform data analysis, data matching and profiling to support decision-making with regards to the activities mentioned above. It may also involve sharing information with third parties who provide a service to us.

This Privacy Policy together with our Cookie Policy applies to all personal data collection and processing activities carried out by Antalpha and its group.

B. COOKIE POLICY

1. IP ADDRESSES

When you use our website or our services, we may collect and store information about your computer (including your IP address, operating system and browser type) for system administration. This is statistical data about our users' browsing actions and patterns. This data could possibly lead to your identification, but we, and our data intermediaries, do not use it to do so unless permitted by law.

2. COOKIES

What is a cookie?

Cookies are small files which are placed on your computer when you access a website or app – amongst other things; they help the website user to navigate efficiently between pages and the website operator to track usage of the site.

You can find out more about cookies at www.allaboutcookies.org .

Why we use cookies

Our website uses cookies to distinguish you from other users of our website by storing, generally non-personally identifiable, information (e.g. session information such as the number of times you visit our website and the location from which you are accessing the website). Note that some limited information is personally identifiable for the purposes of:

a. managing and customizing your experience on the website/platform;

b. analysing trends and improving our site for our users; and

c. delivering content tailored to your interests and the manner in which you browse our websites and platforms.

Any other information is anonymized and/or aggregated to produce statistical reports that enable us to evaluate the use of our website; and to make improvements to, and increase efficiency when you browse our website.

3. WHAT DO WE USE COOKIES FOR?

We use cookies: (i) to track your activities on our website; and (ii) the purposes described in the Privacy Policy, but they will not generally allow us to obtain information of a personal nature such as your name and address. We will only be aware of such information if you provide the information to us or you have set the preferences in your browser to provide this information automatically.

We use the information collected to analyse trends and improve our site for our customers, as more particularly described below.

4. WHAT ARE MY OPTIONS IN RELATION TO THE USE OF COOKIES?

By using our website, apps or platforms, you agree to the use of cookies and other technologies as set out in our Privacy Policy. If you do not agree to such use please either refrain from using the relevant website, app or platform, or see the section below “Can you disable cookies?” to adjust your settings.

You can find more information about the individual cookies we use and the reasons why we use them in the table below.

5. CAN YOU DISABLE COOKIES?

Yes, your browser will enable you to disable, control or delete cookies if you wish. Further information can be found in the “Help” section of your browser or at www.allaboutcookies.org . However, you should note that if you choose to do this, it may have an impact on the quality of your browsing experience.

Please note that changing these settings may limit the functionality of some web pages or prevent them from loading properly. Additionally, the major browsers have attempted to implement the draft “Do Not Track” (DNT) standard of the World Wide Web Consortium in their latest releases. As this standard has not been finalized, this website is not compatible with DNT and does not process DNT messages.

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout

6. THIRD PARTY WEBSITES

Our website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Third parties (including, for example, advertising networks and providers of external services like Google Analytics) may use cookies which are downloaded when you visit our site. These cookies are likely to be analytical, performance or targeting cookies.