Magnitude Markets Privacy and Cookie Policy

This Privacy and Cookie Policy (the “Policy”) explains how the provider of the Interface operating under the Magnitude name (“Magnitude,” “we,” “us,” or “our”) collects, uses, discloses, stores and otherwise processes personal data.

For purposes of Singapore's Personal Data Protection Act 2012 (“PDPA”), Magnitude is the organisation responsible for the personal data described in this Policy. Where another data-protection law applies, Magnitude acts as controller or in the equivalent responsible capacity unless stated otherwise.

This Policy applies to the Magnitude Markets website, mainnet application, APIs, Accounts, communications, referral and rewards programmes, and related services (collectively, the “Interface”).

It should be read with the Mainnet Terms of Use and Restricted Persons and Jurisdictions Policy.

1. Important Information

The Interface uses public blockchain infrastructure. Public Wallet addresses and blockchain transactions can remain permanently visible and may be associated with you by Magnitude or another person.

Magnitude does not require or intend to collect your private key or seed phrase. Never provide either one to Magnitude or a person claiming to represent Magnitude.

2. Personal Data We Collect

Depending on how you use the Interface, we may collect the following categories.

2.1 Account and identity information

• name, alias, username or display name;
• email address, telephone number or other contact information;
• Account identifier and authentication status;
• age or confirmation that you meet the minimum age;
• country, residence, nationality or citizenship information;
• entity name, incorporation information, role and authority to act;
• beneficial ownership and control information;
• professional, accredited, institutional or other investor status; and
• identity or verification results where step-up review is required.

We do not necessarily collect every item from every user. We seek additional identity information only where relevant to access, security, fraud, legal or compliance review.

2.2 Wallet, blockchain and trading information

• public Wallet addresses and Account-to-Wallet associations;
• Wallet connection, agent authorisation and builder-approval information;
• deposits, withdrawals, transfers and public blockchain activity;
• orders, cancellations, fills, positions, collateral, margin, leverage, funding, liquidation and fee information;
• Markets viewed or traded and instructions submitted through the Interface;
• referral codes, referral relationships and reward calculations; and
• blockchain-screening results, risk indicators and related case references.

2.3 Device, network and location information

• IP address and derived country or region;
• VPN, proxy, Tor, relay, hosting and similar network indicators;
• browser, device type, operating system, language, time zone and user-agent information;
• device or browser identifiers, session information and activity logs; and
• security, fraud and authentication indicators.

2.4 Usage and preference information

• pages, Markets, charts, controls and features viewed or used;
• clicks, navigation paths, session duration and performance information;
• Interface, chart, language, theme and cookie preferences;
• diagnostic, crash and error information; and
• aggregated or de-identified product-usage statistics.

2.5 Communications and support information

• messages, support requests, access-review requests and complaints;
• feedback, survey responses and research participation;
• legal notices and dispute communications;
• marketing preferences; and
• documents or other information you choose to provide.

2.6 Referral and rewards information

• referral links and codes used or shared;
• referring and referred Account relationships;
• qualifying activity, points, tiers, rebates and reward status;
• anti-fraud and anti-sybil indicators;
• payment, tax or verification information required to provide a reward; and
• communications and promotional-consent records.

3. Sources of Personal Data

We collect personal data:

1. from you, when you create an Account, connect a Wallet, change a preference, submit an instruction, join a Programme or contact us;
2. automatically, from your browser, device, network and use of the Interface;
3. from public blockchains, Protocol records, smart contracts and public Wallet information;
4. from service providers, including authentication, hosting, geolocation, fraud, sanctions, identity, blockchain-analytics, charting, analytics and support providers;
5. from referral participants, where a person uses or shares a referral code;
6. from public and official sources, including sanctions and export-control lists, corporate registries and government publications; and
7. from affiliates or counterparties, where permitted by law and relevant to the Interface.

4. How We Use Personal Data

We use personal data to provide and secure the Interface; transmit and display instructions and transactions; determine eligibility; apply geographic, sanctions and fraud controls; provide support; administer referrals and rewards; understand and improve performance; communicate with you; comply with law; resolve disputes; and protect users, Magnitude and others.

We process personal data where needed to provide a requested service, comply with legal obligations, pursue legitimate interests such as security and fraud prevention, or with consent where required.

Where consent is the basis, you may withdraw it as described in this Policy. Withdrawal does not affect processing already carried out lawfully and does not prevent processing under another valid basis.

We retain personal data only for as long as needed for the purposes described in this Policy, including applicable legal, security and dispute-related requirements, after which it is deleted or de-identified where feasible.

5. Eligibility, Geoblocking and Automated Decisions

Magnitude uses location, Account, Wallet, device, network, sanctions and fraud information to enforce eligibility and geographic restrictions. Automated tools may assist in allowing, limiting, reviewing or denying access to an Interface feature.

These signals can be incomplete or wrong. A VPN, hosting or indirect Wallet-risk indicator does not automatically prove that a person is prohibited.

Where legally permitted, you may request human review of a restriction by contacting legal@magnitude.markets.

6. Cookies and Similar Technologies

The Interface uses cookies, local storage and similar technologies for authentication, security, user preferences and analytics.

Analytics helps Magnitude understand how the Interface is used, measure performance, identify errors and improve the product.

Where Applicable Law requires consent, analytics Technologies will not be activated before you make a choice. The Interface will provide equally accessible “Accept analytics” and “Reject analytics” options.

You may change your analytics choice through the privacy control available in the Interface.

7. When We Disclose Personal Data

We may disclose personal data to:

• providers that host, secure, authenticate, analyse or support the Interface;
• Hyperliquid, External Market Providers, Wallet providers and other parties involved in an instruction or Market;
• professional advisers;
• authorities or other parties where required by law or necessary to protect rights; and
• parties involved in a financing, reorganisation, sale or transfer of the Interface.

An External Market Provider may process Wallet, order, position, transaction, device or other information independently under the privacy notice identified or linked on the relevant Market page. Magnitude does not control that independent processing merely because the Market is accessible through the Interface.

8. Public Blockchain Data

Blockchain transactions are public by design and may be copied, analysed and retained by any person. Magnitude cannot delete or alter information written to a public blockchain.

If you connect a Wallet, information about that Wallet may be combined with Account, transaction, device or compliance information. Another person may independently associate a Wallet with you.

Using a Wallet involves accepting the public and persistent nature of blockchain data.

9. International Transfers

Magnitude and its service providers may process personal data outside Singapore and outside the country where you are located. Where required, Magnitude uses protections for international transfers under applicable data-protection law.

You may contact the Data Protection Officer for information about applicable transfer safeguards, subject to legal and confidentiality limitations.

10. Security

We use reasonable administrative, organisational and technical measures designed to protect personal data.

No service or method of transmission is completely secure.

11. Your Choices and Rights

Depending on the law that applies, you may have rights to:

• receive information about processing;
• request access to personal data and information about certain uses or disclosures;
• request correction of inaccurate or incomplete personal data;
• withdraw consent with reasonable notice;
• object to or restrict certain processing;
• request deletion where no lawful reason for retention applies;
• receive certain data in a portable format;
• request review of certain automated decisions;
• opt out of marketing; and
• complain to a competent data-protection authority.

These rights are not absolute. For example, we may retain information required for legal obligations, security, sanctions, fraud, transactions, disputes or the rights of another person.

To exercise a right, contact legal@magnitude.markets. We may verify your identity and authority before responding.

Withdrawing consent may prevent use of an optional feature. It does not affect processing necessary to perform a contract, comply with law, protect security or pursue another valid basis.

Singapore access and correction

Where the PDPA applies, you may request access to personal data in our possession or control and information about how it was used or disclosed during the period required by the PDPA. You may also request correction of an error or omission.

You may raise a privacy complaint with our Data Protection Officer. If a concern is not resolved, you may have the right to contact the Personal Data Protection Commission of Singapore.

12. Marketing Communications

We send promotional email, messaging or similar communications only where permitted by law.

You may unsubscribe using the link or instruction in the communication.

Unsubscribing from marketing does not stop essential security, Account, transaction, legal, Market or Programme-administration communications.

13. Children

The Interface is not intended for anyone under 18 or under the age of legal majority where they live.

If we learn that we collected personal data from an ineligible child, we will take reasonable steps to delete or restrict it, subject to legal and security requirements.

Contact legal@magnitude.markets if you believe an ineligible child has provided personal data.

14. Third-Party Links and Services

The Interface may link to a third-party site, Wallet, protocol, social network or service. That third party's privacy notice governs its independent processing.

Magnitude is not responsible for independent third-party privacy practices merely because the Interface contains a link or integration.

15. Changes to This Policy

We may update this Policy. The current version and effective date are shown above.

16. Contact and Data Protection Officer

Privacy, Data Protection Officer, security and support requests may be sent to legal@magnitude.markets.