Privacy Policy

1. Scope

This Privacy Policy applies to the collection and processing of personal information through the Platform.

It applies to:

• Account Registration
• Assessment Application
• Platform KYC
• Assessment Participation
• Trading Analytics
• Data Evaluation
• Data License Fee Administration
• Customer Support
• Platform Security
• Compliance Activities

This Privacy Policy does not apply to third-party websites, blockchain networks, wallet providers, exchanges, or external service providers that maintain their own privacy policies.

2. Information We Collect

Depending on your use of the Platform, we may collect the following categories of information.

A. Account Information

During registration, we may collect:

• Full Name
• Email Address
• Country of Residence
• Username
• Internal User ID
• Password (encrypted)
• Mobile Number (if applicable)

Platform Full KYC is not conducted during general account registration.

B. Identity Verification Information

When you apply for your first Assessment, we may conduct Platform Full KYC.

Information collected may include:

• Government-issued identification
• Selfie image
• Liveness verification
• Date of Birth
• Nationality
• Residential Address
• AML Screening Results
• PEP Screening Results
• Sanctions Screening Results

Platform KYC is generally performed only once unless additional verification is required by applicable law or internal compliance procedures.

C. Trading Data

During Assessment participation, we may collect trading-related information including:

• Trade History
• Orders
• Position Size
• Risk Parameters
• Execution Timing
• Performance Metrics
• Trading Behaviour
• Consistency Metrics
• Analytics Metadata

Trading data is collected solely from activities performed within the simulated trading environment.

D. Payment Information

Where applicable, we may collect:

• Assessment ID
• Payment Method
• Transaction Hash
• Payment Timestamp
• Receipt Information

The Platform does not store private wallet keys.

E. Technical Information

We may automatically collect:

• IP Address
• Device Information
• Browser Type
• Operating System
• Cookies
• Session Information
• Login History
• Usage Logs

3. How We Use Your Information

We use personal information to:

• create and manage user accounts;
• verify identity;
• perform AML and sanctions screening;
• administer Assessments;
• generate Trading Analytics Reports;
• evaluate trading behaviour;
• calculate proprietary evaluation metrics;
• create benchmark datasets;
• develop artificial intelligence and machine learning models;
• create Derived Data;
• improve platform functionality;
• detect fraud and abuse;
• comply with legal and regulatory obligations;
• communicate with users; and
• provide customer support.

4. Trading Data Analytics

The Platform analyses participant-generated Original Data to evaluate trading behaviour and generate proprietary analytical outputs.

Such analysis may include:

• behavioural analysis;
• statistical modelling;
• performance evaluation;
• consistency analysis;
• risk analysis;
• benchmark development;
• artificial intelligence development;
• machine learning development;
• proprietary scoring methodologies; and
• creation of Derived Data.

Derived Data is independently created by the Company through proprietary analytical methodologies, algorithms, statistical models, artificial intelligence systems, and machine learning technologies.

The Company owns all Derived Data and all related intellectual property rights.

These analyses are used for participant evaluation, Trading Analytics, research, service improvement, and the development of Commercial Data Products.

5. Commercial Use of Trading Data

Participation in the Platform grants the Company the non-exclusive Platform Data License described in the Terms of Use.

Under the Platform Data License, the Company may use Original Data for purposes including:

• operating the Platform;
• participant evaluation;
• Trading Analytics;
• benchmark development;
• artificial intelligence development;
• machine learning development;
• research and development;
• creation of Derived Data; and
• service improvement.

The Company may commercialize Derived Data and incorporate Derived Data into Commercial Data Products.

Except where an Exclusive Commercial Data License Agreement has been executed, the Company will not commercialize Original Data as an identifiable standalone dataset or as contributor-specific commercial data.

Where the Company determines that certain Original Data possesses exceptional analytical or commercial value, the participant may be invited to execute a separate Exclusive Commercial Data License Agreement.

Any Data License Fee paid by the Company represents consideration for the exclusive commercial rights granted under that agreement and not for participation in the Platform.

Where commercial licensing occurs, personal identifying information will be removed, anonymized, aggregated, transformed, or otherwise processed in accordance with applicable law and the applicable agreement.

6. Sharing of Information

We may disclose information to:

• identity verification providers;
• AML screening providers;
• cloud infrastructure providers;
• payment service providers;
• blockchain infrastructure providers;
• professional advisers;
• regulators or governmental authorities where legally required; and
• authorized business customers receiving Commercial Data Products.

Commercial Data Products provided to business customers will consist of Derived Data or other appropriately processed information.

Except where authorized under an executed Exclusive Commercial Data License Agreement or required by applicable law, the Company will not disclose Original Data as identifiable contributor-specific commercial data.

We may share personal information, Original Data, Derived Data, compliance records, analytics records, and related information with our parent companies, subsidiaries, affiliates, successors, permitted assigns, and designated intellectual property holding entities within the Company's corporate group for operational, compliance, technology, research, data analytics, intellectual property management, corporate governance, accounting, audit, and business administration purposes.

Where such sharing occurs, the Company will apply appropriate safeguards in accordance with applicable law.

We do not sell personal information.

7. International Data Transfers

Your information may be processed or stored in jurisdictions including:

• Hong Kong;
• United States;
• Singapore;
• European Union;
• other jurisdictions where our service providers operate.

Where required, appropriate safeguards will be implemented for international data transfers.

8. Data Retention

We retain personal information only for as long as necessary to:

• provide the Platform;
• comply with legal obligations;
• maintain compliance records;
• resolve disputes;
• protect our legal rights.

Anonymized or aggregated statistical datasets may be retained indefinitely.

9. Security

We implement reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, or destruction.

No internet transmission or storage system can be guaranteed to be completely secure.

10. Your Rights

Subject to applicable law, you may request:

• access to your personal information;
• correction of inaccurate information;
• deletion of personal information;
• restriction of processing;
• data portability;
• withdrawal of consent where applicable.

Certain requests may be limited where retention is required by law or legitimate business purposes.

11. Cookies

The Platform uses cookies and similar technologies to:

• authenticate users;
• maintain sessions;
• improve security;
• remember preferences;
• analyse Platform usage.

For further information, please refer to our Cookie Policy.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time.

Material changes will be published on the Platform together with the updated effective date.

Continued use of the Platform constitutes acceptance of the revised Privacy Policy.

13. Contact

1IN10 Data Labs Limited Privacy Team Email: privacy@1in10.ai Compliance: compliance@1in10.ai