SignalPlus Privacy Policy

Last Updated: June 27, 2025

We, SignalPlus Limited ("SignalPlus", "Company", "we", "us", "our") are the owners and developers of:

1. the SignalPlus website https://www.signalplus.com/ ("Website"),
2. the SignalPlus mobile application ("App"),
3. the SignalPlus web-facing products/software as a service solutions ("Products"):
   • SignalPlus Trading Dashboard, which integrates all the necessary tools for traders, and
   • Market Making Robot, a fully automated robot with advanced hedging capabilities, enabling efficient management of options trading books with minimal human intervention.

The Website, App and Products are collectively referred to as "Platform".

We respect data privacy rights and are committed to protecting personal data collected on this Website. This Privacy Policy ("Privacy Policy") sets forth how we collect, use and protect the personal data collected on the Platform.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY CLICKING THE CONSENT CHECKBOX AND PROVIDING YOUR CONSENT, YOU CONSENT TO OUR USE OF YOUR PERSONAL DATA IN ACCORDANCE WITH THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, YOU MAY WITHDRAW YOUR CONSENT OR ALTERNATIVELY CHOOSE NOT TO PROVIDE YOUR PERSONAL DATA ON THE PLATFORM. SUCH AN INTIMATION TO WITHDRAW YOUR CONSENT CAN BE PROVIDED BY EMAIL TO privacy@signalplus.com.

IF YOU ARE ACCESSING THE PLATFORM ON BEHALF OF A THIRD PARTY, YOU REPRESENT THAT YOU HAVE THE AUTHORITY TO BIND SUCH THIRD-PARTY TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND, IN SUCH AN EVENT YOUR USE OF THE PLATFORM SHALL REFER TO USE BY SUCH THIRD PARTY. IF YOU DO NOT HAVE SUCH AN AUTHORITY (TO PROVIDE ANY PERSONAL DATA OF A THIRD PARTY) OR DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, THEN YOU SHOULD REFRAIN FROM USING THE PLATFORM.

This Privacy Policy is an electronic record in the form of an electronic contract being compliant and construed in accordance with data protection laws of the applicable jurisdictions.

1. Definitions

1. "User(s)", "you", "yours" shall mean individuals that use/access the Website and/or avails the Products.
2. "Personal Data" shall mean and include any data about an individual who is identifiable by or in relation to such data. This may include but not be limited to, your name, email address, contact number, company name, designation, postal address , location etc.

2. Collection of Personal Data

For purposes of this Privacy Policy, we collect your Personal Data in the following cases:

• Log File Information: Log file information is automatically reported by your browser each time you access a web page. We may collect your personal data through server logs which may include information such as your web request, Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, domain names, landing pages, pages viewed, and other such information. This information may be used for debugging purposes and to improve our Platforms.
• Account Information: When you create an account on the Platform in order to use the Products, you may provide us your Personal Data, including but not limited to, email address, company name, username, password.
• Customer Communications: When you use the Platform, contact us for enquiry or support through our Platform or through email, you may provide us your Personal Data, including but not limited to your name, email address, contact number and company name and any other information you provide to us.

3. Cookies

We use cookies and/or similar in-house and third-party tracking tools to track user traffic patterns. Tracking tools also used are beacons, tags and scripts to collect and track information and to improve and analyze our Website. You may choose to disable cookies through your browser settings. To read our cookie policy, click here.

4. Accuracy of Data

The User undertakes that he shall be solely responsible for the accuracy, correctness, or truthfulness of the Personal Data shared with us whether of its own or any third party. In the event the User is sharing any Personal Data on behalf of a third person, the User represents and warrants that he has the necessary authority to share such Personal Data with the Company, obtained a written consent from such third party and the Company shall not be responsible for verifying the same. The User understands and acknowledges that such Personal Data shall be subject to the terms and conditions of this Privacy Policy.

5. Use of Personal Data

We use the Personal Data for the following purposes:

• to inform you about our Products and to respond to your requests;
• to provide you with a better experience when you access our Website and to improve the Products;
• to maintain and manage our Platform;
• to manage our relationship with you;
• for internal record keeping;
• to generate anonymized, aggregate data;
• and to comply with our legal or statutory obligations;
• for marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you;
• to facilitate transactions.

6. Disclosures

We will not sell, distribute or lease your Personal Data to third parties without your prior consent. Keeping this in mind, we may disclose your Personal Data in the following cases:

• (i) Affiliates: We may provide your Personal Data to our affiliates to enable them to improve our services, provide feedback and respond to their queries.
• (ii) Service Providers: We may share your Personal Data with the service providers who work with us in connection with operating the Website and/ or providing the . All such service providers are subject to stringent confidentiality restrictions consistent with this Privacy Policy.
• (iii) Merger or Acquisition: We may transfer your Personal Data if we are acquired by another entity, or if we merge with another company or transfer a part of our business, including the Products, to a third party. Any such third party or resultant entity that receives your Personal Data shall have the right to continue to use your Personal Data in line with the purposes set out herein. In the event of such a sale or transfer, we may notify you.
• (iv) Legal and Regulatory Authorities: We may disclose your Personal Data in order to comply with our legal obligations/ court orders/ requests by Govt. authorities.

7. Data Retention

We will retain a User's Personal Data for as long as it is required to be retained for the purpose of fulfilling the purposes set out in this Privacy Policy. We may retain and use User's Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We only store your personal data for as long as necessary and we take measures to render the information irrecoverable once deleted.

8. Security

We have implemented reasonable administrative, technical and physical security measures to protect your personal data against unauthorized access, destruction or alteration. Although we provide appropriate firewalls and protections, we cannot guarantee the security of Personal Data transmitted as these systems are not hack proof. Data pilferage due to unauthorized hacking, virus attacks, technical issues is possible, and we will take necessary measures to mitigate such events.

9. Your Rights

You have the right to access Personal Data in our possession, right to have us rectify or modify any such Personal Data, right to have us erase/delete your Personal Data, right to restrict us from processing such Personal Data, right to object to our use of Personal Data, withdraw consent at any time where we are relying on consent to process Personal Data. Depending on the nature of the request, we may ask you to complete a Personal Data request form or seek certain details to verify the request. All requests for Personal Data will be handled within a reasonable period of time. If you would like to exercise ANY of these rights, please contact privacy@signalplus.com.

10. Choice and Opt-Out

We may send you communications and promotional mails including but not limited to (a) notices about your use of our website and services provided on our Website, including those concerning violations of use, (b) updates, (c) promotional information regarding our services, and (d) newsletters. You may opt out of receiving promotional emails and newsletters from us by following the unsubscribe instructions provided in those emails.

However, you will continue to receive administrative messages from us. Alternatively, you can opt out, at any time, by emailing privacy@signalplus.com with your specific request.

11. Information for EU and UK Visitors

Residents of the European Union ("EU") and United Kingdom ("UK") should note that this Privacy Notice has been updated in accordance with the requirements of the EU General Data Protection Regulation (the "GDPR") and the UK GDPR, the United Kingdom Data Protection Act 2018, the Privacy and Electronic Communications Regulations, and any regulation superseding any of the foregoing ("UK Privacy Laws"). As per the provisions of the GDPR and UK Privacy Laws we shall be considered the Controllers of the Personal Data collected as a result of your use / access of the Website and Processors of the Personal Data collected as a result of your use / access of the Services.

Legal Basis (for EU residents and UK residents):

We will not process your Personal Data without a lawful basis to do so. We will process your Personal Data only on the legal bases of consent, contract, or on the basis of our legitimate interests, provided that such interests are not overridden by your privacy rights and interests.

Transfer of your personal Data across borders (for EU Residents):

The Personal Data we collect (of EU and UK residents) is stored on servers located outside the EU region. Personal Data shall be processed outside the EU and UK. We collect and transfer Personal Data outside the EU and UK in accordance with the provisions of the GDPR and UK Privacy Laws. If you have questions, please contact privacy@signalplus.com.

Your Rights (For EU and UK Residents):

You have the right to request us:

1. to let you know what Personal Data belonging to you,
2. we hold in our possession,
3. withdraw consent at any time where we are relying on consent to process your Personal Data,
4. right to have us rectify or modify any such Personal Data,
5. right to have us erase/delete your Personal Data,
6. right to restrict us from processing such Personal Data,
7. right to object to our use of your Personal Data,
8. right to data portability,
9. you have the right to lodge a complaint with a data protection authority.

UK residents have the right to make a complaint at any time to the Information Commissioner's Office ("ICO"), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. We may need to request specific information from you to help us confirm your identity or also contact you for further information in relation to your request. If you would like to exercise ANY of these rights, please contact privacy@signalplus.com.

Governing Laws:

For any EU and UK residents, this Privacy Policy shall be governed respectively by the provisions of the GDPR and UK Privacy Laws.

12. Links to other Websites/Applications

Our Website may contain links to other websites/ applications of your interest. Please note that we do not have any control over such other websites/ applications, and you will be accessing these websites/ applications at your own risk. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites/applications and those are not governed by this Privacy Policy. You should exercise caution and look at the privacy policy applicable to such websites/applications.

13. Children's use

This Website is not meant for children/ person below the age of 18. We do not knowingly collect or solicit Personal Data from children under the age of eighteen (18) years. If a legal representative/ parent of a child discovers that the child has provided us with Personal Data, please write to us on privacy@signalplus.com and we will delete such Personal Data.

14. Governing laws

This Privacy Policy shall in all respects be governed by and construed and enforced in accordance with the laws of Hong Kong and the courts of Hong Kong shall have an exclusive jurisdiction to adjudicate any subject matter under this Privacy Policy.

15. Changes to this policy

Please revisit this page periodically to stay aware of any changes to this Privacy Policy, which we may update from time to time. If we modify this Privacy Policy, we will make it available through the Website and indicate the date of the latest revision. If such modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change via email or through our Website.

Changes to this Privacy Policy apply to your use of our Products after the "last updated" date, at the top.

16. Contact us

If you have any questions or concerns or grievances regarding this Privacy Policy or wish to withdraw your consent in relation to the processing of your Personal Data, you can reach out to our appointed data protection officer, Derek Jiao, via email at privacy@signalplus.com.