Privacy Policy

Effective Date: August 12, 2026

Last Updated: August 12, 2026

This Privacy Policy explains how ARBITAL PTE. LTD., doing business as Arbital ("Arbital," "we," "us," or "our"), collects, uses, discloses, and otherwise processes information when you access or use our websites, applications, trading interfaces, APIs, automated trading tools, social features, and other products and services that link to this Privacy Policy (collectively, the "Services").

This Privacy Policy also describes the choices and rights that may be available to you.

By using the Services, you acknowledge the practices described in this Privacy Policy.

1. Scope

This Privacy Policy applies to information processed by Arbital in connection with the Services.

The Services may allow you to access or interact with third-party exchanges, decentralized exchanges, blockchain networks, brokers, protocols, token issuers, wallet providers, market-data providers, identity providers, and other third-party services.

Those third parties may separately collect and process information under their own privacy policies. Arbital is not responsible for the privacy practices of third parties that we do not control.

2. Information We Collect

The information we collect depends on how you interact with Arbital and which features you use.

A. Information You Provide to Us

We may collect information you provide directly, including:

name;

email address;

username or display name;

profile picture;

social-media account information;

phone number, if provided;

account preferences;

country or region;

communications with our support or team;

survey responses and feedback;

referral or promotional information;

information you post through social or community features;

trading theses, comments, posts, or other user-generated content;

wallet addresses you connect or provide;

exchange or protocol account identifiers;

trading preferences and strategy configurations;

watchlists;

notification settings; and

other information you choose to provide.

B. Trading and Transaction Information

When you use trading-related functionality, we may process information such as:

wallet addresses;

account or subaccount identifiers;

balances made available through connected services;

assets or markets viewed;

orders submitted, amended, or cancelled;

executed trades;

transaction history;

positions;

profit-and-loss information;

trading volume;

strategy settings;

leverage settings;

risk limits;

automated-strategy parameters;

timestamps;

transaction hashes;

blockchain network information;

exchange or protocol used;

referral attribution; and

fees associated with transactions.

Some of this information may already be publicly available on a blockchain.

Arbital may combine publicly available blockchain information with information you provide to us, including information linking a wallet address to an Arbital profile.

C. Connected Accounts and Third-Party Integrations

If you connect Arbital to a wallet, exchange, protocol, social account, authentication provider, or other service, we may receive information from that service.

Depending on the integration, this may include:

account identifiers;

wallet addresses;

authentication tokens;

permissions granted to Arbital;

account balances;

orders and positions;

trading history;

social profile information;

email address;

profile picture; and

information necessary to provide the requested integration.

Where Arbital uses API credentials, OAuth credentials, signing permissions, session keys, or similar authentication mechanisms, we process those credentials only as necessary to provide, secure, and maintain the relevant functionality.

You should never send your wallet seed phrase or private key to Arbital through email, Telegram, social media, or customer support.

D. Identity and Compliance Information

Certain Services, markets, jurisdictions, or third-party providers may require identity verification.

If identity verification is required, Arbital or a third-party verification provider may process information such as:

legal name;

date of birth;

nationality;

residential address;

government-issued identification;

photographs or selfies;

verification results;

sanctions-screening results;

fraud indicators; and

other information required by applicable law or a third-party provider.

Where possible, identity documentation may be collected directly by a verification provider rather than stored by Arbital.

E. Information Collected Automatically

When you use the Services, we may automatically collect:

IP address;

browser type;

device type;

operating system;

device identifiers;

language;

approximate location derived from your IP address;

referring URL;

pages and features viewed;

buttons or links clicked;

session duration;

timestamps;

crash information;

application logs;

performance data;

network information; and

other diagnostic or usage data.

We may use cookies, pixels, local storage, SDKs, and similar technologies to collect some of this information.

F. Public Blockchain Information

Blockchain networks generally operate publicly.

Transactions involving a public blockchain may reveal information such as:

wallet addresses;

token balances;

transfers;

trading activity;

transaction amounts;

smart-contract interactions; and

timestamps.

Blockchain information may remain publicly accessible indefinitely and generally cannot be modified or deleted by Arbital.

G. Public Profiles and Social Trading Features

Arbital may offer profiles, feeds, leaderboards, following, trade discovery, trading theses, performance statistics, or similar social functionality.

Depending on your settings and the relevant feature, information displayed publicly may include:

username;

profile image;

biography;

wallet or account information you elect to make public;

trades;

positions;

assets purchased or sold;

trading theses;

performance metrics;

PnL;

volume;

rankings; and

content you publish.

We may also generate statistics or performance indicators from information available through your connected account or from public blockchain activity.

Where a feature allows you to choose whether information is public, you are responsible for reviewing your privacy settings before using that feature.

Information you make public may be copied, shared, indexed, or stored by other users or third parties outside Arbital's control.

3. How We Use Information

We may use information to:

Provide the Services

Including to:

create and maintain accounts;

authenticate users;

connect wallets and trading accounts;

display portfolios and positions;

transmit user-authorized trading instructions;

operate automated trading strategies;

provide market data;

calculate performance metrics;

operate social features;

maintain watchlists;

route transactions or instructions to third-party providers; and

provide other functionality you request.

Operate and Improve Arbital

Including to:

understand how the Services are used;

diagnose technical problems;

measure performance;

test new functionality;

improve interfaces and recommendations;

develop new products;

conduct analytics; and

maintain infrastructure.

Personalize the Services

We may use information to personalize:

markets displayed;

feeds;

suggested traders;

asset discovery;

content;

notifications; and

other parts of your experience.

Maintain Security and Prevent Abuse

We may use information to:

detect fraud;

prevent unauthorized access;

investigate suspicious activity;

enforce our Terms of Service;

detect manipulation or abuse;

prevent wash trading or other prohibited activity;

protect accounts;

enforce geographic restrictions; and

protect Arbital, our users, and third parties.

Comply With Legal Obligations

We may process information to:

comply with applicable laws;

respond to lawful requests;

enforce sanctions or geographic restrictions;

satisfy regulatory requirements;

establish or defend legal claims; and

cooperate with courts, regulators, law enforcement, or government authorities where legally required.

Communicate With You

We may send:

account notifications;

security alerts;

transaction-related notices;

product updates;

support communications;

policy updates; and

other administrative messages.

Where permitted by law, we may also send promotional communications. You may unsubscribe from promotional emails using the unsubscribe mechanism provided in the message.

4. Legal Bases for Processing

If laws applicable to you require us to identify a legal basis for processing personal information, our legal bases may include:

Performance of a contract. We process information when necessary to provide Services you request.

Legitimate interests. We may process information where necessary for legitimate business purposes such as securing the Services, preventing fraud, improving Arbital, understanding product usage, and operating our business, provided those interests are not overridden by your rights.

Consent. We may rely on your consent for certain processing activities. Where processing is based on consent, you may withdraw that consent as permitted by law.

Legal obligations. We may process information when necessary to comply with applicable law.

5. How We Disclose Information

We may disclose information in the following circumstances.

Service Providers

We may disclose information to companies that help us:

host infrastructure;

provide cloud services;

authenticate users;

secure accounts;

provide analytics;

provide customer support;

send communications;

detect fraud;

process payments;

verify identities;

perform compliance screening; and

operate other parts of the Services.

These providers process information on customer support;

send communications;

detect fraud;

process payments;

verify identities;

perform compliance screening; and

operate our behalf or according to their own legally applicable responsibilities.

Trading Venues and Financial Infrastructure

If you instruct Arbital to access a market or submit a transaction, information may be transmitted to the relevant:

exchange;

decentralized exchange;

protocol;

broker;

liquidity provider;

blockchain network;

wallet provider;

token issuer;

settlement provider;

market-data provider; or

other financial or technical infrastructure provider.

Your interaction with those providers may also be governed by their terms and privacy policies.

Publicly Through Social Features

Information you intentionally publish or elect to make public may be visible to anyone using Arbital and, depending on the feature, potentially to the general public.

Public blockchain activity may also be visible independently of Arbital.

Professional Advisers

We may disclose information to lawyers, accountants, auditors, insurers, consultants, and other professional advisers where reasonably necessary.

Corporate Transactions

If Arbital is involved in a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar corporate transaction, information may be disclosed or transferred as part of that transaction.

Legal and Safety Purposes

We may disclose information where we reasonably believe disclosure is necessary to:

comply with applicable law;

respond to legal process;

enforce agreements;

investigate fraud or security incidents;

prevent illegal activity;

protect the rights, property, or safety of Arbital, our users, or others; or

respond to regulators, courts, or law enforcement.

With Your Direction or Consent

We may disclose information when you direct us to do so or otherwise consent.

6. Sale and Sharing of Personal Information

Arbital does not sell your personal information for money.

Certain analytics, advertising, or tracking technologies may constitute "selling," "sharing," or targeted advertising under some privacy laws even where no money changes hands.

Where applicable law gives you the right to opt out of such processing, Arbital will provide an appropriate mechanism to exercise that right.

We will also recognize legally required browser-based opt-out preference signals where applicable.

7. Cookies and Similar Technologies

We may use cookies and similar technologies for:

authentication;

security;

preferences;

functionality;

analytics;

performance measurement; and

marketing.

Some cookies may be provided by third parties.

Where required by law, we will obtain consent before using non-essential cookies.

You may also be able to control cookies through your browser or device settings. Disabling certain technologies may affect the functionality of the Services.

8. Data Retention

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

provide the Services;

maintain your account;

fulfill the purposes described in this Privacy Policy;

comply with legal obligations;

resolve disputes;

prevent fraud;

enforce agreements; and

protect our legitimate business interests.

Retention periods vary depending on the type of information and why we process it.

When information is no longer reasonably required, we may delete, anonymize, or aggregate it.

Certain information may remain in backups for a limited period.

Information recorded on a public blockchain is outside Arbital's control and may remain publicly available indefinitely.

9. Security

We maintain administrative, organizational, and technical safeguards designed to protect personal information.

However, no online system, blockchain network, software application, database, or method of electronic transmission can be guaranteed to be completely secure.

You are responsible for protecting your:

account credentials;

email account;

connected wallets;

API credentials;

signing devices;

two-factor authentication methods;

private keys; and

recovery phrases.

Please contact us promptly if you believe your Arbital account has been compromised.

10. International Data Transfers

Arbital may operate through service providers and infrastructure located in multiple countries.

As a result, information may be transferred to, processed in, or stored in countries other than the country where you live.

Where required by applicable law, we use appropriate mechanisms intended to protect personal information transferred internationally.

11. Your Privacy Rights

Depending on where you live, you may have rights regarding your personal information, including the right to:

request access;

request correction;

request deletion;

request a copy of certain information;

request restriction of processing;

object to certain processing;

withdraw consent;

opt out of certain targeted advertising;

opt out of certain sales or sharing of personal information;

request data portability;

limit certain uses of sensitive personal information; and

appeal certain decisions regarding a privacy request.

These rights are not absolute and may be subject to exceptions under applicable law.

To exercise a privacy right, contact us at:

[email protected]

We may need to verify your identity before completing a request.

You may also use an authorized agent where permitted by law. We may require evidence that the agent has authority to act for you.

We will not discriminate against you for exercising privacy rights provided by applicable law.

12. European Economic Area, United Kingdom, and Similar Jurisdictions

If applicable data-protection law grants you additional rights, you may have the right to lodge a complaint with the data-protection authority responsible for your jurisdiction.

We encourage you to contact us first so that we can attempt to address your concern.

Where Arbital relies on consent, you may withdraw your consent without affecting processing that occurred before withdrawal.

Where Arbital relies on legitimate interests, you may have the right to object to that processing in certain circumstances.

13. California Privacy Notice

If you are a California resident and the California Consumer Privacy Act, as amended, applies to Arbital's processing of your information, you may have rights including:

the right to know what categories and specific pieces of personal information we collect;

the right to request deletion;

the right to request correction;

the right to know the categories of sources, purposes, and recipients of personal information;

the right to opt out of certain sales or sharing;

the right to limit certain uses or disclosures of sensitive personal information where applicable; and

the right not to receive discriminatory treatment for exercising applicable privacy rights.

The categories of information Arbital may collect are described in Section 2 of this Privacy Policy.

The purposes for which Arbital processes information are described in Section 3.

The categories of recipients are described in Section 5.

14. Children

The Services are not intended for children.

You must be at least 18 years old, or older if the law where you live requires a higher minimum age to use the relevant Services.

We do not knowingly collect personal information from children in violation of applicable law.

If you believe a child has provided us with personal information, please contact us.

15. Third-Party Services

The Services may contain links to or integrations with third-party services.

Arbital does not control how those third parties collect, use, or disclose information.

This Privacy Policy does not apply to information processed independently by those third parties.

You should review their privacy policies before using their services.

16. Changes to This Privacy Policy

We may update this Privacy Policy periodically.

If we make changes, we will update the "Last Updated" date above.

Where required by law, we will provide additional notice of material changes.

Your continued use of the Services after an updated Privacy Policy becomes effective is subject to applicable law.

17. Contact Us

Questions, requests, or complaints concerning this Privacy Policy may be sent to:

Email: [email protected]

For general product or support inquiries:

[email protected]