This Privacy Policy (“Policy”) for HyperTrade (“Company”, “we”, “our”, or “us”) describes the basis on which we may process personal data we may collect from users of the Company’s website, including any of its subdomains (“Website”), in accordance with applicable law. For purposes of applicable data protection laws, the Company is the controller. For the purposes of this Policy, “you” and “your” refers to you as the user of the Website.

Read this Policy carefully so that you understand your rights in relation to your personal data and how we might collect, use, and process it. If you do not agree to this Policy, do not use, access, connect to or interact with the Website, or otherwise provide your information to us.

When you access, use, connect to, or interact with the Website, we may collect certain categories of information about you, including personal data, from a variety of sources.

Information you provide to us:
Data may include: (i) any digital-asset, smart-contract, or protocol address (“Wallet”) information; and (ii) geolocation data. You provide this data to us when you connect your Wallet to the Website.
Other data may include transaction data or history (such as your public blockchain transaction history and other information associated with a linked address or Wallet and token holdings). Should you contact us, we will collect the content of the communications we have with you and any personal data contained within, including the email address you used to contact us.

Information we collect automatically:
When you visit certain pages on our Website, our servers save each access in a log file. The following data may be collected: (i) the date and time of access; (ii) the country from which the website is accessed; (iii) any API endpoints being accessed; (iv) user agent details; (v) the operating system of your computer and the browser you are using (provider, version, and language); and (vi) the transmission protocol used (e.g., HTTP/1.1).
We may use web beacons/clear gifs, geolocation and tracking technologies, and other applications when you visit the Website, including technologies collecting certain information about your access to, use of, connection to, or interaction with the Website (“Usage Data”) that may be integrated with third-party service providers.

In our legitimate interests to provide effective services to you, we may also use this data to create aggregated, anonymized, or de-identified data.

Certain features of the Website may require you to connect a compatible third-party digital Wallet. By using such Wallet, you agree that your access to, use of, connection to, and/or interactions with such third-party Wallets are governed by the policy for the applicable Wallet, and you agree that you are using the Wallet in accordance with the terms and conditions of the applicable third-party provider of such Wallet.

Wallets are not maintained or supported by, or associated or affiliated with, the Company. We expressly disclaim any and all liability for actions arising from your use of third-party Wallets, including but without limitation, actions relating to the use and/or disclosure of personal information by such third-party Wallets.

We generally process the information we collect when we need to do so to perform our contract with you. For example, the processing of this data is carried out for the purpose of enabling your access to, use of, connection to, and interaction with the Website, including: (i) to facilitate your connection to the Website; and (ii) to identify if you are likely to be a Restricted Person, as defined in our general Terms of Use, available at ht.xyz/terms.

With your consent, we may use any data collected, including Usage Data, to tailor features and content to you and to ensure content is presented in the most effective manner for you and your device. We may also use and run analytics to better understand your user experience with respect to the Website.

We may also process this data in our legitimate interests to assist system security and stability, to conduct troubleshooting, data analytics, testing, and research, and to enable optimization and internal statistical analysis, as well as to maintain the safety and security of our users and the Website.

We may use any of your information to comply with legal obligations, enforce terms of use, and protect the Website and our users.

We use cookies to enhance your experience when accessing and using the Website. These cookies are strictly necessary for core functionality and compliance with our Terms of Use. By continuing to use the Website, you consent to their use.

Under applicable data protection laws, you may have certain rights in relation to your personal data. These rights may include the following:

• Right of Access: You have the right to access the personal data we hold about you, including information on how we use it and who we share it with.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal data we hold about you. We may need to verify the accuracy of the new data before making changes.
• Right to Erasure: In certain circumstances, you may request the deletion or removal of your personal data, for example, where there is no good reason for us to continue processing it.
• Right to Object: You may object to our processing of your personal data where we are relying on a legitimate interest (or those of a third party), and there is something about your particular situation that makes you want to object to processing on this ground.
• Right to Restriction of Processing: You have the right to request that we suspend the processing of your personal data in certain circumstances, for example if you want us to establish its accuracy or the reason for processing it.
• Right to Data Portability: You may request that we provide you or a third party with a copy of the personal data we hold about you in a structured, commonly used, machine-readable format. This right only applies to information you have provided to us and where the processing is based on consent or on a contract and is carried out by automated means.
• Right to Withdraw Consent: Where we rely on your consent to process personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing carried out before your withdrawal or processing carried out on other legal bases.

To exercise any of these rights, you may submit a written request to support@ht.xyz. We may ask you to verify your identity before responding. In certain circumstances, we may have legal grounds to refuse your request, and we will inform you if that is the case.

Please note that these rights may only apply in certain situations and may be limited by applicable law. For example, requests may be refused where fulfilling them would adversely affect the rights of others, involve disproportionate effort, or if we are legally required to retain the data.

To the extent required under applicable data protection laws, we will respond to your request without undue delay and at the latest within one month. This period may be extended by two further months if necessary, taking into account the complexity and number of the requests.

In certain circumstances, we may share your personal data with third parties with your consent, as necessary, or as otherwise required or permitted by applicable law. These third parties may include:

• Service Providers and Vendors: We may share your personal data with trusted service providers that perform services on our behalf and under our instructions. This includes, but is not limited to, blockchain analytics providers, infrastructure and node providers, wallet connection services, geo-blocking services (e.g., IPdata), user behavior analytics platforms (e.g., Mixpanel), and content delivery or hosting services. These providers help us operate, maintain, secure, and improve the HyperTrade platform.
• Professional Advisors: We may share personal data with our legal, financial, compliance, and other professional advisors, to the extent necessary and for the purposes of obtaining their professional advice or services.
• Legal and Security Obligations: We may share your information to comply with applicable laws and regulations, respond to lawful requests and legal processes, or protect and defend our rights, interests, safety, or property, and those of our users or third parties. This may include exchanging information with law enforcement, regulatory agencies, or courts.
• Corporate Transactions: If HyperTrade is involved in a merger, acquisition, reorganization, financing, or sale of assets, your personal data may be shared or transferred as part of such a transaction. We will take steps to ensure that any such transfer is subject to appropriate data protection obligations.
• With Your Consent: We may share your data with other parties not listed above when you have given us your explicit consent to do so.

Your personal data may be transferred to, stored in, or processed in countries outside your jurisdiction of residence, including the United Arab Emirates, the European Economic Area ("EEA"), the United Kingdom, and the United States of America. These countries may have data protection laws that are different from those in your jurisdiction. Where applicable, we take appropriate measures to ensure that your personal data remains protected under standards that are equivalent to those required under applicable law, including through data transfer agreements or other legally acceptable safeguards.

We retain your personal data only for as long as is necessary to fulfill the purposes for which it was collected, including to satisfy any legal, regulatory, accounting, or reporting obligations, or as otherwise permitted by applicable law.

The retention period depends on several factors, including:

• The nature of the data collected;
• The context in which the data was collected;
• The purpose for which the data is used;
• Legal or regulatory requirements;
• Whether the data is needed to prevent fraud or maintain security;
• Whether the data is required to establish or defend legal claims.

Where possible, we will anonymize or aggregate your data if we need to retain it for longer periods for statistical purposes or to improve HyperTrade’s functionality. Once retention is no longer necessary, your data will be securely deleted or rendered permanently anonymous.

We will also regularly review the data we hold and assess whether it is still necessary to retain it. If data is no longer needed, we will take steps to securely delete or anonymize it.

HyperTrade is not intended for use by individuals under the age of eighteen (18), and we do not knowingly collect or solicit personal data from children or anyone under the age of 18. By accessing or using HyperTrade, you confirm that you are at least 18 years old or of legal age in your jurisdiction to enter into binding agreements and use digital financial applications.

If we learn that we have inadvertently collected personal information from a person under 18 without verifiable parental consent, we will take commercially reasonable steps to delete such data as quickly as possible from our records and systems.

If you are a parent or guardian and you believe that your child under the age of 18 may have provided personal data to us, please contact us immediately at support@ht.xyz so that we can investigate and take appropriate action.

We employ commercially reasonable administrative, technical, and physical security measures to protect your personal data from unauthorized access, use, loss, destruction, or alteration. These measures are designed to ensure a level of security appropriate to the risks associated with the processing of your personal data.

These measures may include, but are not limited to:

• Use of encryption technologies for data transmission;
• Access controls and authentication protocols to restrict access to systems and data;
• Secure server infrastructure and network protections;
• Routine system audits and vulnerability assessments;
• Logging and monitoring for unusual or unauthorized activity.

Despite our efforts, we cannot guarantee the absolute security of your data. The transmission of information via the Internet is not completely secure, and we cannot ensure or warrant the security of any information you transmit to HyperTrade. Any transmission is at your own risk.

You are responsible for maintaining the confidentiality and security of your wallet credentials, private keys, and any other information necessary to access and use the HyperTrade interface. We strongly recommend that you take appropriate steps to secure your own systems and digital assets, including the use of hardware wallets or other secure storage methods for sensitive information.

While we take reasonable steps to protect your personal data, we cannot guarantee its absolute security. Any data you transmit through the HyperTrade platform may be vulnerable during transit. You acknowledge that such transmissions are made at your own risk.

When you access, use, connect to, or interact with the HyperTrade platform, we and our third-party service providers may collect and log certain data, including technical details about your interactions and your digital signature, as well as any personal data you may have voluntarily provided.

We may provide links on the Website to other websites or online platforms operated by third parties, including social media or content platforms such as X (formerly Twitter), Medium, or Discord (“Social Media Platforms”). We may also provide links to websites or online platforms operated by third-party contributors, partners, or integrations associated with HyperTrade. These websites and services are not operated or controlled by us, and we do not assume responsibility for their content, data practices, or availability. If you choose to visit these websites, you do so at your own risk. You should review the privacy policies and terms applicable to those third-party services before interacting with them.

Third parties and ecosystem contributors may offer services, analytics tools, widgets, dashboards, or integrations accessible via the Website or from Social Media Platforms. These services are independently operated and are not affiliated with HyperTrade or its developers. We do not control or endorse any third-party services, nor are we responsible for the accuracy, completeness, reliability, or legality of the content, tools, or data provided by such third parties. Any inclusion of links or references to third-party websites or tools does not imply any endorsement by us unless explicitly stated on the Website.

When you access a Social Media Platform link from the Website, a direct connection may be established between your browser and the platform's servers, which may allow the platform to collect data about your visit and associate it with your profile, especially if you are logged in at the time. If you do not wish your activity to be linked in this way, you should log out of the relevant platform before clicking on external links. Any interaction you have with a third-party website or Social Media Platform is governed solely by that platform’s terms, and HyperTrade disclaims any liability for the actions or policies of such third parties.

This Policy reflects our commitment to complying with applicable data protection and privacy regulations, including, but not limited to, the data protection laws of the United Arab Emirates (“UAE”), Panama’s Law No. 81 of 2019 on Personal Data Protection, and, where applicable, the European Union’s General Data Protection Regulation 2016/679 (“EU GDPR”) and the United Kingdom’s General Data Protection Regulation (“UK GDPR”).

If you are a resident of the European Economic Area (“EEA”), the United Kingdom, or any other jurisdiction with similar data protection frameworks, you may have additional rights in relation to your personal data. These may include the right to lodge a complaint with a supervisory authority if you believe your rights under data protection laws have been violated.

We reserve the right to periodically review and revise this Policy to reflect changes in our data processing practices, regulatory obligations, or technology. Any updates will become effective upon publication of the revised Policy on the Website at https://ht.xyz/. The “Last updated” date at the top of the Policy will be updated accordingly. We encourage you to review this Policy from time to time to remain informed about how we protect your personal data.

By continuing to use the HyperTrade interface after changes to this Policy are posted, you acknowledge and agree to the revised terms. If you do not agree with the updated Policy, you should discontinue all use of the Website and associated services.

If you have any questions, concerns, or complaints regarding this Privacy Policy, our data-handling practices, or your personal data, please contact us by email at support@ht.xyz. We will endeavor to respond promptly and address your inquiry in accordance with applicable data protection laws.