This Privacy Policy sets out how Alta Alternative Investments Pte. Ltd. ("Alta") manages information or Personal Data (as defined in the Personal Data Protection Act 2012 and related legislation (collectively, the “PDPA”) as updated from time to time) you may provide when you access and use this Website or any of Alta's Services or products. This Privacy Policy forms part of the Website Agreements together with the Terms of Use, and all capitalized terms that are used but not defined in this Privacy Policy have the meaning given to them in the Terms of Use. We reserve the right to change, modify, add, or delete any part of this Privacy Policy at our sole discretion at any time.In accessing or using the Website or any Service, you agree to be bound by, and will be deemed to have read, understood, and agreed to the practices and policies outlined in, this Privacy Policy as updated from time to time. If at any time you disagree with any part of this Privacy Policy, please promptly discontinue your access to or use of the Website or Services. Please also note that if you do not provide us with any of the information we request, or withdraw your consent to us collecting and using your Personal Data, we may not be able to provide, or continue providing you with, access to or use of the Website or Services.If you access or use the Website or Services on behalf of another individual (such as your child) or an entity (such as your employer), you represent that you are authorised by such individual or entity to (i)accept this binding Privacy Policy on such individual’s or entity’s behalf, and(ii) consent on behalf of such individual or entity to our collection, use, and disclosure of such individual’s or entity’s information as described in this Privacy Policy.This Privacy Policy does not apply to Third Party Sites you may access through, or in the course of your use of, the Website or Services.Your rights in relation to those third parties will be governed entirely by the privacy statements or terms and conditions of those Third Party Sites.

For purposes of this Privacy Policy, “Personal Data” has the same meaning as set out in the PDPA and generally refers to information that can identify you when taken alone or together with other information. This includes information such as your name and contact details.

We collect Personal Data through various means, including when you:
· voluntarily provide the same to us;
· contact us or request that we contact you;
· access or use the Website;
· access, use, or request for any Services; and
· interact with any of our employees.
Alta shall not knowingly collect or attempt to collect your Personal Data through fraudulent, unlawful, or deceptive practices.

We collect, use, or disclose your Personal Data:
· for the specific purpose(s) for which the Personal Data was provided;
· to enable us to perform our contractual or other obligations to you or any other person accessing or using the Website or Services;
· to comply with any law or regulation applicable to us or request from any regulator, court, or other authority;
· to operate, monitor, improve, or administer the Website or Services;
· to provide you with access to the Website;
· to provide you with the Services or any other services you may request;
· to respond to or otherwise contact you; and
· for any other purpose that that a reasonable person would consider appropriate in the circumstances. Alta shall not knowingly use your Personal Data for, or to facilitate, any fraudulent, unlawful, or deceptive purpose.

Alta may be required to disclose your Personal Data to its affiliates or to third parties where:
· your have consented to (or may reasonably be deemed to have consented to) such disclosure;
· necessary or otherwise reasonably required to maintain or provide continued access to the Website, the Services, or any other services you may request;
· necessary or otherwise reasonably required for Alta to comply with its legislative or regulatory obligations, any request from a regulator, government body, or other authority, or Alta's own processes and policies;
· necessary or otherwise reasonably required for Alta to perform its obligations under the Website Agreements or other agreements binding upon it;
· necessary or otherwise reasonably required to respond to you, contact you, or otherwise address your requests;
· Alta has reason to believe that doing so will be appropriate or necessary for it to investigate and defend against any third party claims or allegations, or prevent or stop any illegal activity, security breaches, or harm to the Website, Alta's interests, or any Alta employee;
· Alta is the subject of a takeover and your personal information forms part of Alta's assets to be transferred to the acquiring entity; or
· you disclose such information to third parties in the course of accessing or using the Website.

You are responsible for maintaining the accuracy of the Personal Data you submit to us. If your Personal Data changes, you may correct it, delete inaccuracies, or amend it by making the relevant changes in your account or by contacting us at privacy@alta.exchange. We will make good faith efforts to make requested changes in our then-active databases as soon as reasonably practicable. If you provide any information that is or becomes, or that we may reasonably suspect is, untrue, inaccurate, out of date, or incomplete, we may at our sole discretion discontinue your access to or use of the Website or Services.There may be circumstances where Alta will not correct, delete or update your Personal Data, including where the Personal Data (a) is opinion data that is kept solely for evaluative purpose or (b) must still be retained for a business or legal purpose.

We may from time to time be required to transfer PersonalData collected in accordance with this Privacy Policy to locations outside Singapore (e.g., due to the physical locations of our servers). If such transfer is required, Alta will comply with its obligations under the PDPA for as long as the Personal Data remains in Alta's possession or under Alta's control during the transfer. Alta will also take appropriate steps to ensure that the recipient located outside Singapore is legally obliged(e.g., through contractual obligations) to provide to the Personal Data with a level of protection comparable to that required under the PDPA.We will retain your Personal Data for as long as required for the purpose(s) for which it was collected and for our compliance with legal obligations on recordkeeping imposed upon us as a regulated financial institution under Singapore law. Generally, we do not retain Personal Data for a period of longer than six (6) years after the original purposes for which the Personal Data was collected have ceased to be applicable, unless otherwise required by law or other mandatory directions by court or government authorities or for purposes of legal proceedings or other similar proceedings or investigations. We may also aggregate or anonymise your Personal Data solely for analytic purposes. In such a case, you will no longer be identifiable from the aggregated or anonymised Personal Data, and we may retain such data for as longer as we require.

Alta has taken reasonable measures to ensure the security of your Personal Data stored with us, whether in electronic or physical form.This includes protecting your Personal Data from improper or unauthorised access, use, disclosure, modification, appropriation, destruction, and loss. Nevertheless, you acknowledge and agree that communications through the Internet are inherently insecure and all Personal Data you transfer to Alta via the Internet is done so at your sole risk. Alta does not warrant, represent, guarantee, or otherwise assure that the Personal Data you provide will never be accessed, copied, used, or disposed of in breach of Alta's security measures, and you agree not to hold Alta or any of its affiliates liable or responsible for any loss or damage resulting therefrom. In the event of such a breach, Alta will, as far as reasonably possible, promptly notify all affected persons.Alta is not responsible, and will not be held liable, for any damage or loss, or misuse, theft, or other compromise of Personal Data, arising directly or indirectly from any unauthorised use of or access to any Member’s electronic devices used to access or use the Website or Services.

A cookie is a text file that a web page server stores in your local browser cache. Alta uses cookies for various purposes, including strictly necessary cookies (required to operate the Website); analytical cookies (to perform analytics on how people access and browse the Website); functionality cookies (that recognise you and enable Alta to customise your user experience on the Website); and targeting cookies (that record your visits to and movement on the Website for purposes of making advertisements shown to you more relevant to your interests). Third parties (such as analytics software) may also use cookies for performance or targeting purposes. Alta has no control over cookies from third parties.You may change your browser settings to decline any or all cookies when accessing the Website. You may also delete stored cookies by changing your browser settings. However, please note doing so may adversely affect your access to or use of the Website. For example, you may not be able to fully load all features or functionalities of the Website. Alta shall not be held liable for any loss or damage resulting from deletion or rejection of cookies.Your Internet Service Provider allocates an IP address to your computer so that it may access the Internet. IP addresses may be dynamic (i.e., they change each time you connect to the Internet) or static (i.e., specific to your computer). Alta may collect this IP address to facilitate its administration of the Website, including by diagnosing server problems and collecting aggregated information.

Subject to the exceptions referred to in s 21(2) of the PDPA, you have the right to request a copy of your Personal Data we hold. Please send your request for such a copy to privacy@alta.exchange. We may impose an administrative charge for this.If you no longer agree to Alta using your Personal Data to contact you for non-essential communications (such as promotional and marketing-related information regarding the Services), you may let us know by changing your account settings or sending an email to privacy@alta.exchange.You may request that Alta deletes your Personal Data under certain circumstances, such as when you withdraw your consent to our use, collection, disclosure, transfer, or storage of your Personal Data as set out in this Privacy Policy. However, please note that we may not always be able to accede fully to such requests, including where we are required to comply with other legal obligations on retaining your Personal Data.Please note that should you withdraw consent as described above, Alta may not be able to provide you with Services or access to the Website. You acknowledge and agree that Alta may cease such access or provision promptly without any liability.

You may contact our Data Protection Officer at privacy@alta.exchange should you have any further queries.

This Privacy Policy is governed by and shall be construed in accordance with the laws of Singapore. Any dispute arising out of or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Singapore.