Privacy Policy

Introduction

This Privacy Policy is part of the Talis Trade Terms of Service. All terms, conditions, and terminology are consistent with the Terms of Service, and the Terms of Service are incorporated into this document by reference.

This policy governs the use of the Talis Trade mobile application and associated tools and services (collectively, the “Services”). The operator may offer other products and services.

The Services do not include outside websites or platforms which may be linked or interconnected to the Services. Such outside platforms may have their own terms of service and privacy policies, which control for all transactions and data processing on such platforms. These outside platforms may include, but are not limited to, the Hyperliquid interface at app.hyperliquid.xyz and wallet infrastructure providers.

Simpliphi Ventures Pte. Ltd., a company incorporated in Singapore, operates the Services. It and its affiliates are referred to in this document as the “operator,” “we,” or “us.”

The Blockchain

Blockchain technology, also known as distributed ledger technology (or simply ‘DLT’), is at the core of our business. Blockchains are decentralized and made up of digitally recorded data in a chain of packages called ‘blocks’. The manner in which these blocks are linked is chronological, meaning that the data is very difficult to alter once recorded. Since the ledger may be distributed all over the world across several nodes which usually replicate the ledger, there is no single person making decisions or otherwise administering the system, and there is no centralized place where it is located either.

This means that by design, a blockchain’s records cannot be changed or deleted and is said to be ‘immutable’. This may affect your ability to exercise your rights such as your right to erasure (‘right to be forgotten’), or your rights to object or restrict processing, of your personal data. Data on the blockchain cannot be erased or changed. Although smart contracts may be used to revoke certain access rights, and some content may be made invisible to others, it is not deleted.

In certain circumstances, in order to comply with our contractual obligations to you, it will be necessary to write certain personal data, such as your wallet address, onto the blockchain. In most cases, ultimate decisions to transact on the blockchain using your wallet address, as well as share the public key relating to your wallet address with anyone (including us), rest with you.

If you want to ensure your privacy rights are not affected in any way, you should not transact on blockchains as certain rights may not be fully available or exercisable by you or us due to the technological infrastructure of the blockchain. The blockchain is available to the public and any personal data shared on the blockchain will become publicly available.

Individuals under the Age of 18

As per our Terms of Service, individuals under the age of 18 are not permitted to use the Services. As such, we do not knowingly collect, solicit, or maintain personal data from anyone under the age of 18 or knowingly allow such persons to register for the Services.

In the event that we learn that we have collected personal data from an individual under age 18, we will use commercially reasonable efforts to delete that information from our database. If you are a parent or guardian and become aware that your child has shared personal data with our Services, please contact us so that we may remove such data. Note that we cannot delete information stored on public cryptographic blockchains.

Collecting

Information and content you provide

We collect the content, communications, and other information you provide when you use our Services, including when you create an account, initiate use of the Services, or communicate with others. This information may include, but is not limited to:

• Name
• Address
• Email
• Phone number
• Government-issued identification number (or equivalent)
• Financial information
• Date of birth
• Citizenship
• Payment information
• Information used to verify your identity

If required to help us verify your identity, you may provide us a copy of your driver’s license, passport, or other government-issued ID. If required to help us verify your residence, you may provide us with a utility bill, lease, or other proof of residence. You may also provide other verification documents, such as bank statements reflecting the source of funds, to meet applicable anti-money laundering laws, regulatory requirements, or other legal requirements. By providing verification information and documents, you also provide us information within those records, which may include characteristics of protected classifications such as your sex, age, national origin, and citizenship.

Financial information

In order to transfer funds, you may need to provide us and our third-party financial providers or partners with certain account and other payment information. You may agree to your personal and financial information being transferred, stored, and processed by such third parties in accordance with their respective privacy policies.

Wallet information

The Services use third-party wallet infrastructure to create and manage your digital wallet. Your wallet address and related authentication information are collected and managed by our wallet infrastructure provider in accordance with their terms of service and privacy policy. We collect your wallet address and transaction data in connection with your use of the Services.

AI features

When you use AI-powered features within the Services, including natural language trading tools, we collect the inputs you provide and information about the outputs generated. This information is used to provide and improve the Services. We may use third-party AI infrastructure providers to process these inputs. See the Third-Party Data Collection section for more information.

Your usage

We collect information about how you use our Services, such as the types of content you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.

Information about transactions

If you use our Services for transactions of any kind, we collect information about them, including transaction amounts, asset types, timestamps, and related identifiers.

Device information

We collect information from and about the devices you use to interact with our Services, including:

• Device operations: information about operations and behaviors performed on the device
• Identifiers: unique identifiers, device IDs, and other identifiers
• Network and connections: information such as your mobile operator or ISP, language, time zone, IP address, and connection speed
• Cookie data: data from cookies stored on your device, including cookie IDs and settings
• Information necessary to enable push notifications

Cookies

We, and our partners, use cookies and similar technologies to give you the best possible experience. Cookies are used to remember you and to collect information about how you interact with the Services. If you have an account with the Services, we may link this usage data with other information. You may have the option to accept or refuse these cookies. If you choose to refuse, you may not be able to use some portions of the Services.

When using the Services

When using the Services, we may collect and process personal data stored in different instances. We collect and use this information to provide you the Services and to debug issues and provide support.

On the blockchain, the following data may be stored: addresses of externally owned accounts, transactions made, and token balances. Given the technological design of the blockchain, this data will become public and it will not be possible to delete or change the data.

On our servers, we store the following data: addresses of externally owned accounts, transactions made, log data, IP address, and transaction IDs and hashes.

Tracking and Uses

We use the information we have (subject to choices you make) as described below and to provide and support the Services:

Provide, personalize, and improve our Services

We use the information we have to deliver our Services, including to personalize features and content. We use the information we have to develop, test, and improve our Services, including by conducting surveys and research, and testing and troubleshooting new products and features, including AI-powered features.

Provide measurement, analytics, and other business services

We use the information we have (including your activity on our Services) to help partners measure the effectiveness and distribution of their services, and understand the types of people who use their services and how people interact with them.

Promote safety, integrity, and security

We use the information we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Services, and promote safety and security.

Communicate with you

We use the information we have to send you marketing communications, communicate with you about our Services, and let you know about our policies and terms. We also use your information to respond to you when you contact us.

Because recognition of the Do Not Track HTTP header feature of your web browser is not standardized, the Services do not recognize it for tracking purposes.

All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Third-Party Data Collection

Third parties may collect or receive certain information about you and/or your use of the Services to provide functionality, analytics, or to measure and analyze performance, in or through the Services. These third parties include:

Wallet Infrastructure Provider

We use a third-party provider to manage embedded wallet creation, key storage, and authentication. This provider collects and processes information necessary to create and secure your wallet, including your authentication credentials (such as email address or social login). Their privacy policy governs the processing of data within their platform.

On-Ramp Provider — fun.xyz

Deposit and on-ramp functionality is provided by fun.xyz. When you use deposit features, you interact with fun.xyz’s platform, which collects and processes payment and identity information subject to their privacy policy.

AI Infrastructure Providers

AI-powered features within the Services are powered by third-party AI infrastructure providers. Inputs submitted to AI features may be processed by these providers in accordance with their terms and privacy policies. We take reasonable steps to limit retention and use of your data by these providers.

Analytics and Monitoring Providers

We use third-party providers for product analytics and application monitoring. These providers may collect device identifiers, usage data, and technical information about your use of the Services in accordance with their privacy policies.

Cloud Infrastructure

The Services are hosted on third-party cloud infrastructure. Data stored on our servers is subject to those providers’ data processing terms.

Other Providers

We may engage additional third-party service providers from time to time to support the operation of the Services. We will update this policy to reflect material changes to our third-party data sharing.

Retention

The Services may keep the information we gather about you for an unlimited length of time, subject to applicable law. Where law requires us to retain certain data for a minimum period (such as transaction records under anti-money laundering regulations), we will comply with those requirements. Where law permits deletion, we will honor valid deletion requests to the extent technically feasible.

To request that information collected about you be deleted, please contact us at the email provided in this policy. A valid request must include sufficient information to identify your personal data. Note that we cannot delete information stored on public cryptographic blockchains.

Sharing

The Services only share information about you with others as follows:

We may transfer your personal data to a third party as a result of a business combination, merger, asset sale, reorganization, or similar transaction, or to governmental authorities when we reasonably believe it is required by law or appropriate to respond to legal process.

We will also share your information with third-party companies, organizations, or individuals if we have a good faith belief that access, use, preservation, or disclosure of your information is reasonably necessary to detect or protect against fraud or security issues, enforce our terms of use, meet any enforceable government request, defend against legal claims, or protect our legal rights or the safety of users.

To operate the Services, we share information about you as needed with our service providers, including financial institutions, accountants, auditors, lawyers, payment processors, wallet infrastructure providers, AI infrastructure providers, analytics providers, information technology consultants, advisors, and our affiliates. We only share information to the extent required to fulfill our obligations to you and to regulators, and to operate the Services.

We routinely share information with companies closely related to us — our ‘affiliates’ — for certain purposes under this policy.

We may share information about you with regulators, including those in Singapore, the United States, or other applicable jurisdictions, where we believe doing so is required or appropriate to comply with any laws, regulations, or other legal processes, such as court orders, search warrants, or subpoenas.

The Services may contain links to third-party websites. Third-party websites are not under our control, and we are not responsible for their accuracy, completeness, or reliability. Please be aware that when you enter a third-party website, any information you provide is subject to the terms and privacy policy of that website.

Opt-Out

If you wish to stop receiving marketing or promotional communications or to opt out of use of your information for the purposes described in this policy, please follow the opt-out instructions in those communications, such as clicking ‘Unsubscribe.’ You can also contact us at support@simpliphiventures.com to opt out.

Despite your indicated preferences, we may send you service-related communications, including notices of updates to our terms or this policy. You will not be allowed to opt out of certain communications required to comply with applicable laws, rules, and regulations.

Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. We limit access to your personal data to those who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Contact

If you have comments or questions about the privacy practices of the Services, contact us at:

support@simpliphiventures.com

Simpliphi Ventures Pte. Ltd., Singapore

Changes

The Services may change this privacy policy at any time. Check the latest version within the app or at our website. Continued use of the Services following any update constitutes acceptance of the revised policy.