PRIVACY POLICY

SIGMA FINANCE AI – ARBITRAGE TRADING PLATFORM

Last Updated: 24 June, 2025

1. Introduction

Welcome to Sigma Finance (“Sigma Finance”, “we”, “us”, or “our”)

Sigma Finance AI provides an AI-powered arbitrage trading platform that connects with supported cryptocurrency and/or financial exchanges to help users automate trading strategies (the “Service”)

• This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you:

• Visit our website(s),

• Use our web or mobile application(s),

• Connect your exchange account(s) or wallet(s),

• Interact with our AI trading bots and related tools, or

• Communicate with us in any way,

By accessing or using the Service, you acknowledge that you have read and understood this Privacy Policy and agree to its terms. If you do not agree, please do not use the Service.

2. Scope of This Privacy Policy

This Privacy Policy applies to:

• Users of the Sigma Finance platform (web, mobile, APIs, and trading bots),

• Visitors to our website(s),

• Individuals who communicate with us (e.g., via email, support tickets, or social channels).

• It does not apply to:

• Third-party exchanges or brokers you connect to our platform,

• External websites, services, or applications you may access through links from our platform.

• Those providers have their own privacy policies, and we strongly recommend you review them.

3. Information We Collect

We may collect the following categories of information:

3.1. Information You Provide Directly

Account registration data

Name or username

Email address

Password (stored in encrypted form)

Country/region (if requested)

Verification / compliance data (if applicable)

ID information (e.g., government ID, passport)

Proof of address

Date of birth

Any information required under KYC/AML regulations (if we are legally required to collect it or if you submit it voluntarily).

Exchange connection data

API keys (key & secret) for supported exchanges

Exchange account identifiers (e.g., exchange user ID)

Permissions/settings for trading and read-only access

Note: We do not request withdrawal permissions in API keys where not necessary and strongly encourage users to keep withdrawal access disabled on exchange APIs

Payment/billing data (if applicable)

Payment method details (processed via payment providers)

Billing address

Transaction history for subscription or service payments

Communication data

Messages sent to our support team

Feedback, surveys, and other communications

3.2. Information We Collect Automatically

When you access or use the Service, we may automatically collect:

Device and connection data

IP address

Browser type and version

Operating system and device type

Language and time zone

Usage data

Pages visited, features used, and time spent on the platform

Clicks, scrolls, and interaction with UI elements

Session logs and access timestamps

Log data

Login attempts and authentication logs

API errors and system performance logs

Security events (e.g., unusual access patterns)

3.3. Trading & Bot Activity Data

To provide the arbitrage and trading functionality, we may process:

Connected exchange accounts and selected markets

Bot configurations and parameters

Order history (including prices, sizes, timestamps)

Trade execution details and PnL data

Balance and position information retrieved from exchanges via your API keys

3.4. Cookies & Similar Technologies

We may use cookies and similar technologies (e.g., local storage, pixels) to:

Remember your login and preferences

Maintain session security

Analyze traffic and platform performance

Improve user experience and features

You can manage cookies through your browser settings, but disabling certain cookies may limit the functionality of the Service.

4. How We Use Your Information

We may use your information for the following purposes:

To provide and operate the Service

Authenticate your account and manage access

Connect and manage your exchange integrations

Execute trading strategies and bots you configure

Display trading data, history, analytics, and performance

To improve and optimize the platform

Monitor usage patterns and performance

Develop new features, strategies, and tools

Conduct research, testing, and AI model improvements (in de-identified or aggregated form where possible)

To communicate with you

Send account-related notifications (e.g., security alerts, system updates)

Respond to your inquiries and support requests

Provide information about new features, updates, or offers (where permitted)

To ensure security and prevent abuse

Detect and prevent fraud or unauthorized access

Monitor for suspicious activity

Enforce our Terms of Use and other policies

To meet legal and regulatory obligations

Comply with applicable financial, anti-money laundering (AML), and counter-terrorist financing (CTF) regulations (if applicable)

Respond to lawful requests from authorities or regulators

For analytics and business operations

Analyze platform usage and performance metrics

Generate aggregated, anonymized statistics

Support internal reporting, planning, and risk management

5. Legal Bases for Processing (If in GDPR/Similar Jurisdictions)

We do not sell your personal data.

We may share your data with:

Service providers / processors

Cloud hosting and infrastructure providers

Analytics and monitoring tools

Customer support platforms

Payment processors and billing services

Connected exchanges and third-party platforms

When you authorize Sigma Finance to access an exchange via API, we transmit relevant trading instructions and may receive account/trading data from that exchange.

Your data on those platforms is governed by their own policies.

Professional advisors

Lawyers, auditors, or consultants under confidentiality obligations.

Authorities and regulators

When required to comply with applicable law, regulation, legal process, or enforceable government request.

Business transfers

In connection with a merger, acquisition, restructuring, or sale of all or part of our assets, your data may be transferred as part of that transaction, subject to confidentiality and applicable laws.

We will take reasonable steps to ensure that any third parties receiving your data process it in a manner consistent with this Privacy Policy and applicable law.

6. How We Share Your Information

We do not sell your personal data.

We may share your data with:

Service providers / processors

Cloud hosting and infrastructure providers

Analytics and monitoring tools

Customer support platforms

Payment processors and billing services

Connected exchanges and third-party platforms

When you authorize Sigma Finance to access an exchange via API, we transmit relevant trading instructions and may receive account/trading data from that exchange.

Your data on those platforms is governed by their own policies.

Professional advisors

Lawyers, auditors, or consultants under confidentiality obligations.

Authorities and regulators

When required to comply with applicable law, regulation, legal process, or enforceable government request.

Business transfers

In connection with a merger, acquisition, restructuring, or sale of all or part of our assets, your data may be transferred as part of that transaction, subject to confidentiality and applicable laws.

We will take reasonable steps to ensure that any third parties receiving your data process it in a manner consistent with this Privacy Policy and applicable law.

7. International Data Transfers

Depending on where you are located, your data may be transferred to and processed in countries other than your own, including countries that may have different data protection laws.

Where required, we implement safeguards such as:

Standard contractual clauses (SCCs), or

Other legally recognized transfer mechanisms,

to protect your personal data in cross-border transfers.

8. Data Retention

We retain your personal data only as long as necessary to:

Provide the Service and maintain your account,

Fulfill the purposes described in this Policy,

Comply with legal, accounting, and regulatory obligations,

Resolve disputes and enforce agreements.

Typical retention guidelines (subject to change):

Account data – retained while your account is active and for a reasonable period after closure, as required by law or to maintain records.

Trading & bot data – retained as long as needed for service provision, analytics, compliance, and legal obligations.

Logs and security data – kept for a limited period for security and troubleshooting, unless needed longer for investigations.

When data is no longer needed, we will take reasonable steps to delete or anonymize it.

9. Security Measures

We take appropriate technical and organizational measures to protect your data, including:

Encryption in transit (e.g., HTTPS/TLS) and, where appropriate, at rest

Secure storage of API keys in encrypted form

Access controls and role-based permissions for internal staff

Regular monitoring and logging for suspicious activity

Backups and disaster recovery planning

No system can be 100% secure, and we cannot guarantee absolute security. However, we work continuously to protect your information and improve our security practices.

10. Your Rights & Choices

Depending on your jurisdiction, you may have some or all of the following rights:

Access – Request a copy of your personal data we hold.

Rectification – Ask us to correct inaccurate or incomplete data.

Erasure – Request deletion of your personal data (subject to legal and contractual limitations).

Restriction – Ask us to limit processing in certain circumstances.

Data portability – Request transfer of your data in a structured, commonly used format.

Objection – Object to processing based on legitimate interests or direct marketing.

Withdraw consent – Where processing is based on consent, you can withdraw that consent at any time.

11. Third-Party Links & Services

The Service may contain links to third-party websites, exchanges, wallets, or services that we do not operate or control. This Privacy Policy does not apply to those third parties.

We are not responsible for the privacy practices of any third-party services. We encourage you to review their privacy policies before sharing personal data or connecting your accounts.

12. Marketing Communications

Where permitted by law, we may send you emails about:

Platform updates and new features

Educational content, tips, and market insights

Promotions or offers related to Sigma Finance

You can opt out at any time.

Please note: you may still receive service-related emails, such as security alerts, system notifications, or account messages.

13. Automated Decision-Making & Profiling

Our Service uses algorithms and automated systems to:

Analyze market data,

Execute arbitrage strategies, and

Generate signals or trading decisions.

These automated processes are core to the Service’s functionality. However:

You maintain control over enabling/disabling bots and setting parameters.

We do not use automated decision-making to make legal or similarly significant decisions about you as an individual (e.g., credit scoring) outside the context of trading operations.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in:

Laws and regulations,

Our services and features,

Our internal processes.

When we make changes, we will:

Update the “Last updated” date at the top, and

Where appropriate, notify you via email or in-app notice.

Your continued use of the Service after any changes become effective signifies your acceptance of the updated Privacy Policy.