Privacy Policy

Last Updated: April 10, 2025

Introduction

This Privacy Policy ("Policy") explains how AlloyX Group (Hong Kong) Limited ("AlloyX Group", "we", "us" or "our") collects, uses, stores, shares and protects your information when you access or use our websites, mobile applications, APIs, smart‑contract interfaces or any other products and services we operate, including the AXG and related tooling (collectively, the "AlloyX Group Services").
This Policy supplements any jurisdiction‑specific notices or product‑specific disclosures we may provide and does not override them.

Who Is Providing This Notice

AlloyX Group is committed to protecting and respecting your privacy. For transparency, the AlloyX Group entities on whose behalf this Privacy Policy is made are:
  • AlloyX Group (Hong Kong) Limited; and where applicable, any affiliated general partner, manager, and/or investment adviser of a relevant token issuance or investment vehicle (collectively, the AlloyX Group Parties).
  • When we use the terms "we", "us", and "our" in this Policy, we are referring to AlloyX Group and the AlloyX Group Parties.
  • Please consult your subscription documentation, token purchase agreement, private placement memorandum, or other offering materials provided by or on behalf of the AlloyX Group Parties for the entities and contact details relevant to our relationship with you. We welcome holders of AXG and their representatives to contact us if they have any queries with respect to which AlloyX Group Parties are relevant to their relationship with AlloyX Group.
When you provide us with your Personal Data, each AlloyX Group Party that decides how and why Personal Data is processed may be acting as a “data controller.” This means the AlloyX Group Party makes decisions on how to use and protect your Personal Data, but only to the extent that we have informed you about such use or are otherwise permitted by law.

The Data We Collect About You

Category
Examples
Identity Data
First, middle, and last name, date of birth, nationality, ID/passport number, tax ID, gender
Contact Data
Residential and billing address, email address, and telephone numbers
Financial & Blockchain Data
Bank account details, blockchain wallet address and provider, AXG holdings, transaction hashes, and fees paid
Transaction Data
Amount, date/time, recipient, on/off‑ramp details
Technical & Usage Data
IP address, device type, operating system, browser type and version, cookies, interaction logs
Profile & Marketing Data
Username, preferences, feedback, survey responses, marketing opt‑ins
Location Data
City‑level geolocation derived from IP
Aggregated/Anonymised Data
Statistical or demographic data that cannot identify you
We do not intentionally collect special categories of sensitive personal data (e.g., health, biometric, or political opinions).

How We Collect Data

  • AlloyX Group (Hong Kong) Limited; and where applicable, any affiliated general partner, manager, and/or investment adviser of a relevant token issuance or investment vehicle (collectively, the AlloyX Group Parties).
  • Automated technologies – cookies, server logs, smart‑contract events.
  • Third‑party or public sources – analytics vendors, identity‑verification providers, banking partners, and public blockchains.

Why We Process Your Data

PurposeLegal Basis
Provide and operate AlloyX Group ServicesContract performance
Prevent fraud and secure systemsLegitimate interest
Process transactions and settlementsContract performance
Communicate service updates and account noticesLegal obligation / Legitimate interest
Marketing of products and events (opt out any time)Consent / Legitimate interest
Analytics and product improvementLegitimate interest
Comply with audits, tax, and regulatory requestsLegal obligation
We rely on consent only where required by local law (e.g., sending third‑party marketing emails). You may withdraw consent at any time.

Sharing Your Data

We may share your data with:
  • AlloyX Group group entities and affiliates
  • Banking and payment partners
  • Custodians, administrators, auditors, legal and professional advisers
  • Identity verification and AML service providers
  • Cloud hosting, analytics and communication vendors
  • Regulators, tax authorities and law‑enforcement agencies
  • Prospective assignees or acquirers in business transactions
We do not sell personal data for monetary consideration.

International Transfers

Your data may be transferred to and processed in countries outside your jurisdiction (including but not limited to Hong Kong, Singapore, the EU, the UK, and the United States). Where required, we implement appropriate safeguards such as Standard Contractual Clauses or obtain your explicit consent.

Data Retention

We retain personal data for as long as necessary to fulfil the purposes outlined in this Policy, including legal, accounting, and regulatory requirements, and will securely delete or anonymise it thereafter.

Security

AlloyX Group employs administrative, technical, and physical safeguards—encryption, access controls, firewalls—to protect your data. No system is 100 % secure; you are responsible for securing your wallet credentials.

Your Rights

Depending on your jurisdiction, you may have rights to access, correct, delete, restrict, object to or port your data, or withdraw consent. Submit requests viaprivacy@alloyx.group.We will verify your identity and respond within the statutory timeframe.

Cookies & Tracking

We use cookies and similar technologies for site functionality, security, and analytics. You can disable cookies in your browser, but parts of the AlloyX Group Services may not function properly. We do not respond to Do‑Not‑Track signals at this time.

Children

AlloyX Group Services are not directed to persons under 18. We do not knowingly collect personal data from minors. If we learn that we have inadvertently done so, we will delete such data promptly.

Changes to This Policy

We may update this Policy periodically. Material changes will be noted via email or a prominent notice on our website. Continued use of AlloyX Group Services after the effective date constitutes acceptance of the revised Policy.

Contact Us

Email: privacy@alloyx.group
If you have questions, concerns, or wish to exercise your rights, please contact us.
This Policy is provided for information only and does not constitute legal advice. Please consult professional counsel to ensure compliance with all applicable laws.

The RWA Lite platform serves as a technical interface designed to help partner institutions present project information and enable essential on-chain interactions. Its purpose is to offer a lightweight environment where asset issuers can showcase project highlights, provide wallet connection, display token balances, and support basic token transfers and transaction history. The platform does not engage in investment advisory, fundraising, asset management, or any form of financial service. It does not provide custody, does not handle user funds, and does not perform full KYC/KYB/KYW/KYT regulatory procedures. All project descriptions, asset characteristics, expected returns, and related information displayed on the platform are provided directly by partner institutions. The platform ensures proper technical presentation and maintains consistent display of such information, but the commercial substance, legal compliance, and associated risks of the underlying project remain the responsibility of the respective issuer.


All on-chain actions initiated by users—including token transfers, wallet signature operations, transaction broadcasting, balance queries, and blockchain record retrieval—are executed directly on public blockchain networks. Once confirmed on-chain, transactions are irreversible. Any losses arising from incorrect input, network delays, gas settings, contract risks, or other blockchain-related factors must be borne by the user, as the platform cannot modify or cancel blockchain transactions. The platform operates in a non-custodial manner and does not store, access, or manage users’ private keys, seed phrases, or wallet credentials. Users are solely responsible for securing their own wallets. Any loss resulting from credential mismanagement, third-party wallet malfunctions, malicious software, phishing attacks, or other external cybersecurity threats is outside the platform's scope of responsibility.


Additionally, the platform relies on third-party blockchain node providers, external blockchain explorers, and independent wallet tools for certain functions. Temporary service disruptions, delays, or inconsistencies may occur due to network conditions, system upgrades, or the inherent characteristics of decentralized infrastructure. While the platform strives to maintain stable functionality, such risks cannot be entirely eliminated. By using the RWA Lite platform, users acknowledge and accept that the platform serves solely as a technical tool for project presentation and basic on-chain interactions. It does not provide guaranteed returns, principal protection, or investment recommendations. Users should carefully assess their own risk tolerance and, when necessary, seek professional legal or financial advice before engaging in any asset-related activity.

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