Privacy Rights
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Privacy Policy

Updated June 2024
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Introduction
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RIOT CAPITAL PTE. LTD ("we," "us," or "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, and protect your personal data when you use our website RiotXAI.com. When using our services, as a resident of one of the EU member states, we shall process personal data of our customers (“you,” “your,” or the “Customer”) as follows. This Privacy Policy (the “Policy”) provides you with information about how your data are processed.
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In this Privacy Policy, you will find information regarding the following:

1. Who is the controller of your personal data and whom to contact?

2. What information do we collect about you and how do we obtain it?

3. How do we use your personal data?

4. How do we store personal data and how are they secured?

5. To whom do we make your personal data available?

6. Do we transfer your data to third countries and international organizations?

7. What are your rights and how can you exercise them?
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1. WHO IS THE CONTROLLER OF YOUR PERSONAL DATA AND WHOM TO CONTACT?

The controller of personal data is RIOT CAPITAL PTE. LTD, with its registered office at 7 TEMASEK BOULEVARD, #12-07, SUNTEC TOWER ONE, Singapore 038987. (hereinafter referred toas “we,” “our,” “our Company,” or “Controller”).

You can contact RIOTCAPITAL PTE. LTD at Support@riotxai.com regarding any questions and the exercise of rights relating to the processing of your personal data.

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2. WHAT INFORMATION DO WE COLLECT ABOUT YOU AND HOW DO WE OBTAIN IT?

In this section, you can read general information about which of your personal data we collect and how we collect it. Detailed information on the purposes for which we process personal data is given in Section 3 of this Policy. All information on the basis of which we can directly or indirectly identify you or which is related to you is considered personal data.

We obtain most of the data we collect about you directly from you in connection with your use of our services. This includes, in particular:

- Data that you provide to us yourself: This includes information you provide when registering on the website, entering information into your user account, ordering services, participating in our events and projects, or communicating with us through customer support or social networks. These data include identification and contact details such as your name, surname, telephone number, e-mail address, postal address, date of birth, username and password, business identification number or tax registration number (if you are an entrepreneur), payment data (such as bank details), and other data such as records of communication between you and our company or details of any warranty claims.

- Data that we automatically collect when you use our services: These data include information about your device (such as IP address, device type, operating system, browser used, connection provider), website usage data (such as date, time and duration of visit, country from which you visit the website, website browsing history), and data on the use of services (such as login and logout information, your account settings, value of your fictitious capital, your account currency, business strategy).

- Data provided by third parties: This includes data from providers of trading platforms that you choose to use with our services, and social network operators if you decide to link your social networking accounts to an account on the website. These data include information about the simulated transactions you have completed (such as the type of financial instrument, time of opening and closing the position, amount of investment, profit and loss) and data from social networks (username, profile picture, e-mail address associated with the account on the social network).
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3. HOW DO WE USE YOUR PERSONAL DATA?

We use personal data for the following purposes:

- Registration and user account: To register on the website and create your account, and for this purpose, we process your personal data. Personal data: identification and contact data; we may also process your data related to the settings of your user account. Legal ground for processing: Processing is necessary for the performance of the contract.

- Provision of services and exercise of rights and obligations under the contract: To provide you with our services, relevant access, tools, and support, and to carry out trades. Personal data: Identification and contact data and, in the case of paid services, also payment data, data on the use of the services, data on simulated trades, and data from social networks (if linked). Legal ground for processing: Processing is necessary for the performance of the contract or based on our legitimate interest.

- Marketing communication: If you are a current or past customer, we may send you marketing communications that relate to our services or events. Each e-mail will contain a link to easily unsubscribe. Personal data: Identification and contact data. Legal ground for processing: Legitimate interest or consent.

- Customer support and communication: To provide customer support services. Personal data: Identification data, contact data, other data, and data from social networks (if you contact us through social networks). Legal ground for processing: Legitimate interest.

- Improving services: To develop, test, enhance services, and improve security. Personal data: Identification and contact data, data about your device, website usage data, data on the use of services, and data on simulated trades. Legal ground for processing: Legitimate interest.

- Analytics: To obtain information about how our website and services are used and to analyze customer behavior. Personal data: Identification data, contact data, payment data, data about your device, website usage data, data on the use of services, and data on simulated trades. Legal ground for processing: Legitimate interest.
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4. HOW DO WE STORE PERSONAL DATA AND HOW ARE THEY SECURED?

We process your personal data in an encrypted database on computers and other devices. To ensure protection against unauthorized access or alteration, disclosure, or destruction of the data, we have adopted organizational and technical measures to secure them, which we strictly adhere to.
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5. HOW LONG DO WE PROCESS YOUR DATA?
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Personal data are processed to the extent necessary to fulfill the purposes described above and for the time necessary to achieve those purposes or for a period directly stipulated by law. Thereafter, the personal data are deleted or anonymized. We process personal data for the following periods of time:

- Performance of the contract: For the necessary period, but not more than 10 years from the termination of the last contract.

- Business communications without consent:For a maximum of 5 years from the expiry of the last contract or until you raise an objection or unsubscribe.

- Enhancing services: For a maximum period of 6 months.

- Legal obligations: For the period set out by the relevant legal regulations (e.g., in accordance with tax regulations for a period of 10 years from the issuance of the relevant documents).

- Consent: For the period specified in the consent.
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6. DATA SHARING AND TRANSFERS TO THIRD COUNTRIES

We make your data available or transfer them to persons that help us provide our services, in particular the following persons:

- The trading platform provider: To enable you to perform simulated trades.

- Other third parties: Who help us run our website and provide our services (such as companies in our group, hosting and cloud service providers, payment system operators, financial institutions, providers of customer support tools and services, IT companies, system administrators, marketing and communication agencies, consultants, and postal service providers).

- Other persons: With your consent or as required by law or judicial decision. Each entity to whom personal data are transferred is contractually obligated to protect your personal data in accordance with legal provisions and to process the data exclusively according to our instructions.
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Certain third parties collect personal data for their own purposes as controllers. In such a case, their own rules for the processing of personal data shall apply.
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7. YOUR RIGHTS

You can exercise all your rights mentioned below, including your right to erasure of personal data and the withdrawal of your consent, by sending a request to us via email at Support@riotxai.com. There are no specific words that you must use in your request, but please be specific enough so we can help you with your request (e.g., identify yourself, specify the right you wish to exercise, what action you wish us to take, details of what personal data you want erased/deleted, etc.).

In connection with the processing of personal data you have the following rights:

- Right of access to personal data: You can ask us at any time to send you a confirmation as to whether or not your personal data are being processed. If we process your data, we will provide you with further details on the processing. If you request it, we will also provide you with a copy of the personal data processed. Please note that the first copy is free of charge, but later copies will be provided for a small fee.

- Right to rectification of personal data: If we process your personal data inaccurately, you can notify us of this fact, and we will rectify the inaccurate personal data without undue delay. If you register on the Website, you will be able to rectify and amend your personal data yourself by editing your user account.

- Right to erasure of personal data (“right to be forgotten”): You have the right to obtain from us the erasure of personal data concerning you without undue delay in the following cases:

 - If the data are no longer necessary in relation to the purposes for which we have collected or otherwise processed them;

 - If you withdraw your consent to their processing and, at the same time, there will be no other legal ground for their processing (this only applies in the cases where we process personal data on the basis of your consent);

 - If you object and there are no overriding legitimate grounds for the
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processing, or if you object to the processing for direct marketing purposes; or

 - If your personal data are processed unlawfully.

 - We will not be able to act on the request for the erasure of personal data if their processing is necessary for exercising the right of freedom of expression and information, for compliance with any of our legal obligations, for the performance of a task carried out in the public interest, for the establishment, exercise, or defense of our legal claims, or for other reasons provided for by law.

- Right to restriction of processing: In cases stated in article 18 of the GDPR, you have the right to obtain from us restriction of processing of your personal data for a certain period.

- Right to data portability and to the provision of data in a machine-readable format: In the case of automated processing based on your consent or performance of the contract, you have the right to receive the data in a structured, commonly used and machine-readable format and to have them transmitted by us to another personal data controller.

- Right to object: If we process personal data on the basis of our legitimate interest, you have the right to object to such processing. If you file such an objection, we will not be able to process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests or rights and freedoms, or for the establishment, exercise, or defense of our legal claims.

 - In case we process your personal data for marketing purposes about our products and services, we will terminate the processing without undue delay upon receipt of the objection. In such a case, we will no longer be able to send you offers of our products and services.

- Right to withdraw consent: If processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on the consent given before its withdrawal.

- Right not to be the subject of automated decision-making: Except where processing is necessary for entering into, or performance of, a contract, where this is permitted by applicable law, or based on your express consent, you have the right not to be the subject of any decision which is based solely on automated processing, including profiling, which produces legal effects concerning you or similarly affects you to a significant extent.
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8. FINAL PROVISIONS

We may change this policy unilaterally, but we will do so only when necessary and we will notify you about such change. You can find the latest version of this policy in your Client Section.

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