Privacy Policy

Date Last Revised: 29 June 2023

We recognise our responsibilities in relation to the collection, holding, processing, use and/or transfer of personal data (to the extent we collect any). Your privacy is of utmost importance to us.

This privacy policy (โ€œPolicyโ€) outlines how we collect, use, store and disclose your personal data. Please take a moment to read about how we collect, use and/or disclose your personal data so that you know and understand the purposes for which we may collect, use and/or disclose your personal data. By accessing the website at and any sub-domains (โ€œWebsiteโ€), you agree and consent to Zeta Protocol Platform Corp, its related corporations, business units and affiliates, as well as their respective representatives and/or agents (collectively referred to herein as โ€œZetaโ€, โ€œweโ€, โ€œusโ€, โ€œourโ€), collecting, using, disclosing and sharing amongst themselves the personal data, and to disclosing such personal data to relevant third party providers. This Policy supplements but does not supersede nor replace any other consent which you may have previously provided to us nor does it affect any rights that we may have at law in connection with the collection, use and/or disclosure of your personal data. We may from time to time update this Policy to ensure that this Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, the prevailing terms of this Policy shall apply. For the avoidance of doubt, this Policy forms part of the terms and conditions governing your relationship with us and should be read in conjunction with the Terms and Conditions (โ€œTerms and Conditionsโ€).

The security of your personal data is important to us. At each stage of data collection, use and disclosure, Zeta has in place physical, electronic, administrative and procedural safeguards to protect the personal data stored with us. However, do note that no transmission of personal data over the internet can be guaranteed to be 100% secure โ€“ accordingly and despite our efforts, Zeta cannot guarantee or warrant the security of any information you transmit to us, or to or from our online services.

This Policy describes how Zeta may collect, use, disclose, process and manage your personal data (to the extent we collect any), and applies to any individualโ€™s personal data which is in our possession or under our control.

1. What personal data is collected by Zeta "Personal data" means data, whether true or not, about an individual from which that individual can be identified. Some examples of personal data that Zeta may collect are:

a) Contact data, such as your name and email address; b) Financial data, such as particulars of your digital wallet address, transaction history of that digital wallet address, public cryptographic keys relating to digital wallet addresses on distributed ledger networks;

c) Transaction data, such as information about the transaction you make on our Website, type of transaction, transaction amount and timestamp; d) Technical data, such as internet protocol (IP) address, geographical location, browser type and version, browser plug-in types and versions, operating system and other technology on the devices you use to access the Website; e) Usage data, such as information about your use of our services and Website, and specific user interactions with the Website such as user preferences, features utilised, areas visited or clicked on, pages visited, time and date of your visit, time spent on each page, and other diagnostic data; f) Correspondence data, such as your feedback, questionnaire and survey response and information provided to our support teams, including via email or social media messaging channels; g) Data we get from others. We may get data about you from other sources as required or permitted by the applicable law, including public databases. We may combine data collected from these sources with the data we collect from the Website in order to comply with our legal obligations to prevent use of the Website in connection with fraud and financial crime and to respond to requests from regulators etc.

Personal data may be collected when you interact with our services or use the Website, or may be received by Zeta from third-party databases or service providers that provide business information.

2. Purposes for collection, use and disclosure of your personal data Zeta may collect, use and/or disclose your personal data for its business purposes, including operations for these purposes. These may include, without limitation, the following: a) Providing products or services. We may use the data we collect to provide, develop, maintain, personalise and improve products or services (whether made available by us or through us), including as described in the Terms and Conditions. This includes without limitation data to: i) operate, maintain, measure and improve the Website and Interface (as defined in the Terms and Conditions) that enable the trade of token-referenced Options, Futures and Perps (in each case, as defined in the Terms and Conditions); ii) create and update user accounts; iii) process transactions and conduct any necessary reporting on these transactions; iv) complete technical maintenance and bug fixes; v) conduct analytics for the purposes of developing or improving our products, services, security and service quality; and vi) send information, including confirmations, notices, updates, security alerts and support messages. b) Customer support. We may use the data we collect to assess and process questions, feedback, complaints or requests from you or our customers including to direct questions to appropriate customer support team members, to investigate and address questions and improve our customer support service. c) Marketing and communication. We may use the data we collect to market our Website, Interface and services to you and communicate updates. This may include providing you with updates on changes to the Interface, services or products (whether made available by us or through us) including any additions, expansions, suspensions and replacements of or to such services or products and their terms and conditions. If you don't want us to send you marketing communications please opt out by selecting โ€œunsubscribeโ€ to any marketing email sent by us or contact [email protected]. d) Security. We may use your data to maintain the security and safety of our Website, Interface and services including to: i) maintain our infrastructure and business operations and complying with internal policies and procedures; ii) prevent, detect, investigate, deter and report any unauthorised or illegal activity, including fraud and any form of financial crime; iii) address any violation of our Terms and Condition or any other agreements for other products and services; iv) enforce obligations owed to us, protect our rights or property, and protect against legal liability; v) comply with applicable security laws and regulations. e) Legal and regulatory compliance. We may use the data we collect to: i) verify your identity for the purposes of providing facilities, products or services, which would require comparison of your personal data against third party databases and/or provision of such information to third party service providers as may be required under applicable law, regulation or directive; ii) conduct credit checks, screenings or due diligence checks as may be required under applicable law, regulation or directive; iii) complete financial reporting, regulatory reporting, management reporting, risk management, audit and record keeping; iv) comply with all applicable laws, regulations, rules, directives, orders, instructions and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities; v) seek professional advice, including legal or tax advice. f) Research and development. We may use the data we collect to monitor the Website, Interface, products and services provided by or made available through us and carry out research, planning, testing and statistical analysis on these. g) Other. We may also use the data we collect to enable any actual or proposed assignee or transferee, participant or sub-participant of Zeta's rights or obligations to evaluate any proposed transaction.

We may also use personal data for purposes set out in the Terms and Conditions that govern our relationship with you or our customer.

3. Disclosure and sharing of personal data We may from time to time and in compliance with all applicable laws on data privacy, disclose your personal data to any personnel of Zeta, group entities, or to third parties (including without limitation banks, financial institutions, credit card companies, credit bureaus and their respective service providers, companies providing services relating to insurance and/or reinsurance to us, and associations of insurance companies, agents, contractors or third party service providers who provide services to us such as telecommunications, information technology, payment, data processing, storage and archival, and our professional advisers such as our auditors and lawyers, and regulators and authorities), located in any jurisdiction, in order to carry out the purposes set out above. Please be assured that when we disclose your personal data to such parties, we require them to ensure that any personal data disclosed to them are kept confidential and secure.

We may share your data in the following circumstances: a) With your consent. We may share your data when you have given us consent to do so, for instance for marketing uses. b) To comply with our legal obligations. We may share your data to: i) cooperate with local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities; ii) comply with a court order or similar legal procedure; iii) report suspect illegality activity such as fraud or financial crime; iv) address any violation of our Terms and Condition or any other agreements for other products and services. c) With service providers or other third parties. We may share your data with service providers or third parties who help facilitate business and compliance operations, such as marketing and technology services. d) During a change in our business. If we engage in a merger, acquisition, bankruptcy, dissolution, reorganisation, sale of some or all of our assets or stock, acquisition of all or a portion of our business, some or all of your data may be shared or transferred subject to standard confidentiality arrangements.

For more information about the third parties with whom we share your personal data, you may, where appropriate, wish to refer to the agreement(s) and/or terms and conditions that govern our relationship with you or our customer. You may also contact us for more information (please see Section 8 below for contact details). We wish to emphasise that Zeta does not sell personal data to any third parties and we shall remain fully compliant of any duty or obligation of confidentiality imposed on us under the applicable agreement(s) and/or terms and conditions that govern our relationship with you or our customer or any applicable law.

Accuracy of data. You are responsible for ensuring that the personal data you provide to us is accurate, complete, and not misleading and that such personal data is kept up to date. You acknowledge that failure on your part to do so may result in our inability to provide you with the products and services you have requested. To update your personal data, please contact us (please see Section 8 below for contact details). Where you provide us with personal data concerning individuals other than yourself, you are responsible for obtaining all legally required consents from the concerned individuals and you shall retain proof of such consent(s), such proof to be provided to us upon our request.

Transfer of data. We may transfer, store, process and/or deal with your personal data in any jurisdiction, and accordingly such personal data may be transferred to computers, servers or hardware located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. Zeta will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy and no transfer of your personal data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information. Your consent to this Policy followed by your submission of such information represents your agreement to the transfer of personal data as described herein.

4. Retention of personal data We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements

We may need to retain data for a longer period where we need the data to comply with regulatory or legal requirements including but not limited to investigating and reporting fraud and financial crime and responding to requests from regulators. When we no longer need to use personal data, we will remove it from our systems and records and/or take steps to anonymise it so that you can no longer be identified from it.

5. Cookies and related technologies The Website uses cookies. A cookie is a small text file placed on your computer or mobile device when you visit a website or use an app, which may include an anonymous unique identifier. Cookies

collect information about users and their visit to a website or use of a app, such as their IP address, how they arrived at a website (for example, through a search engine or a link from another website), how they navigate within a website or app, browser information, computer or device type, operating system, website usage, referring/exit pages, date/time stamp and number of clicks.

We use cookies and other technologies to facilitate your Website sessions, offer you products and/or services according to your preferred settings, track use of our Website and to compile statistics about activities carried out on our Website.

Examples of cookies which we use include without limitation:

a) Session Cookies. To operate our Website. b) Preference Cookies. To remember your preferences and settings. c) Security Cookies. For security purposes.

You may set up your web browser to block cookies from monitoring your website visit. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies you may not be able to use certain features and functions of our Website.

We further utilise a variety of other similar tracking technologies, including without limitation beacons, tags, and scripts to collect and track information and to improve and analyse our services.

6. Other websites Our Website may contain links to other websites which are not maintained by Zeta. This Policy only applies to the website of Zeta. When visiting these third party websites, you should read their privacy policies which will apply to your use of such websites.

7. Queries, Access/Correction Requests and Withdrawal of Consent If you: a) have queries about our data protection processes and practices; b) wish to request access to and/or make corrections to your personal data in our possession or under our control; or b) wish to withdraw your consent to our collection, use or disclosure of your personal data,

please submit a written request (with supporting documents, if any) to our Data Protection Officer at: [email protected]. Our Data Protection Officer shall endeavour to respond to you within 30 days of your submission. Please note that if you withdraw your consent to any or all use or disclosure of your personal data, depending on the nature of your request, we may not be in a position to continue to provide our Website, services or products to you or administer any contractual relationship in place. Such withdrawal may also result in the termination of any agreement you may have with us. Our legal rights and remedies are expressly reserved in such an event.

We may charge you a fee for processing your request for access. Such a fee depends on the nature and complexity of your access request. Information on the processing fee will be made available to you upon request.

8. Contact information To contact us on any aspect of this Policy or your personal data or to provide any feedback that you may have, please contact our Data Protection Officer at [email protected].

9. Governing law and jurisdiction This Policy and your use of the Website shall be governed and construed in accordance with the laws of Singapore. You agree to submit to the exclusive jurisdiction of the Singapore courts.

10. Amendments and updates to Zeta Privacy Policy We reserve the right to amend this Policy from time to time to ensure that this Policy is consistent with any developments to the way Zeta uses your personal data or any changes to the laws and

regulations applicable to Zeta. We will make available the updated Policy on the Website. You are encouraged to visit the Website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection. All communications, transactions and dealings with us shall be subject to the latest version of this Policy in force at the time.

11. For European Union or European Economic Area Residents This Section 11 applies if you are an individual located in the European Union or European Economic Area. Subject to applicable law, you have the following additional rights in relation to your personal data:

a) the right to be informed about the collection and use of your personal data; b) the right to access and receive a copy of your personal data and other supplementary information; c) the right to have inaccurate personal data rectified or completed if it is incompleted; d) the right to have personal data erased in certain circumstances; e) the right to request that organisations restrict their use of your personal data; f) the right to data portability which allows you to obtain and reuse your personal data for your own purposes across different services; g) the right to object to the processing of your personal data in certain circumstances; h) the right to be free from decisions based solely on automated processing of your personal data, unless such processing is necessary for entering into, or the performance of, a contract between you and us or you provide your explicit consent to such processing; i) the right to make a data protection complaint.

If you believe that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your residence, your place of work or the place of the alleged infringement. You may exercise any of your rights in relation to your personal data by contacting our Data Protection Officer at: [email protected].

12. Your acceptance of these terms This Policy, alongside other relevant notices and clauses, governs the collection, use and disclosure of your personal data by us. We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated.

By using the Website and/or any services provided by Zeta, you signify your acceptance of this Policy and the Terms and Conditions. If you do not agree to this Policy or Terms and Conditions, please do not use the Website, Interface or any services provided by Zeta. Your continued use of the Website following the posting of changes to this Policy will be deemed your acceptance of those changes.

Last updated