Data Protection Officer Contact:
Email: [email protected]
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Privacy Policy
Unhedged Raffles Platform
Effective Date: January 1, 2026
Last Updated: August 13, 2026
1. Introduction
Alpha DNA Private Limited ("Company," "Unhedged," "we," "us," or "our"), a company incorporated in Singapore, is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Unhedged raffle platform (the "Platform").
This Privacy Policy is designed to comply with the Personal Data Protection Act 2012 of Singapore ("PDPA") and other applicable data protection laws.
By accessing or using the Platform, you consent to the collection, use, and disclosure of your personal data as described in this Privacy Policy.
2. Data Protection Officer
In accordance with the PDPA, we have appointed a Data Protection Officer (DPO) to oversee our data protection practices.
For any questions, concerns, or requests regarding your personal data, please contact our DPO.
3. Information We Collect
3.1 Information You Provide
Wallet Information:
- Public wallet address (required for Platform access)
- Wallet connection signatures
KYC/AML Information (if applicable):
- Full legal name
- Date of birth
- Nationality
- Residential address
- Government-issued identification documents
- Proof of address documents
- Selfie or biometric data for identity verification
- Source of funds documentation
Communications:
- Support inquiries and correspondence
- Feedback and survey responses
3.2 Information Collected Automatically
Device and Technical Information:
- IP address
- Device type, operating system, and browser type
- Unique device identifiers
- Referring URLs and exit pages
- Time zone and language settings
- Screen resolution
Usage Information:
- Pages and features accessed
- Raffle rounds viewed and entered
- Transaction history (from public blockchain records)
- Time spent on the Platform
- Interaction patterns and preferences
Blockchain Information:
- Public wallet addresses involved in transactions
- Transaction history (publicly available on Canton Network)
- Raffle entry amounts and round participation
- Payout history
3.3 Information from Third Parties
Blockchain Data:
- Publicly available transaction information from Canton Network
KYC/AML Service Providers:
- Identity verification results
- Sanctions screening results
- PEP (Politically Exposed Person) check results
Analytics Providers:
- Aggregated usage statistics
- Performance metrics
4. Purposes of Data Collection and Use
We collect and use your personal data for the following purposes:
4.1 Platform Operation
- Facilitating your access to and use of the Platform
- Processing and recording raffle entries and payouts
- Maintaining your account and transaction history
- Providing customer support
4.2 Legal and Regulatory Compliance
- Complying with applicable laws and regulations
- Conducting KYC/AML verification
- Responding to legal requests and court orders
- Preventing fraud, money laundering, and terrorist financing
- Enforcing our Terms of Service
4.3 Security and Protection
- Protecting the Platform from unauthorized access
- Detecting and preventing fraud and abuse
- Investigating suspicious activity
- Ensuring the security of user funds
4.4 Platform Improvement
- Analyzing usage patterns to improve the Platform
- Developing new features and services
- Conducting research and analytics
- Troubleshooting technical issues
4.5 Communications
- Sending service-related notifications
- Responding to inquiries and support requests
- Providing updates about the Platform
- Marketing communications (with your consent)
5. Legal Basis for Processing
We process your personal data on the following legal bases:
| Purpose | Legal Basis |
|---|---|
| Platform operation | Consent; Contractual necessity |
| KYC/AML compliance | Legal obligation |
| Security and fraud prevention | Legitimate interests |
| Platform improvement | Legitimate interests |
| Marketing communications | Consent |
| Legal proceedings | Legal obligation; Legitimate interests |
6. Data Sharing and Disclosure
6.1 Third-Party Service Providers
We may share your personal data with third-party service providers who assist us in operating the Platform:
| Category | Purpose | Data Shared |
|---|---|---|
| Cloud Infrastructure | Hosting and data storage | All data |
| KYC/AML Providers | Identity verification | KYC information |
| Analytics Providers | Usage analysis | Usage data (anonymized where possible) |
| Security Services | Fraud detection | Device and transaction data |
| Customer Support | Support services | Communication data |
All service providers are contractually obligated to protect your data and use it only for specified purposes.
6.2 Blockchain Networks
By using the Platform, you acknowledge that:
- Transactions are recorded on the Canton blockchain
- Wallet addresses and transaction data are publicly visible
- Blockchain records are immutable and cannot be deleted
6.3 Legal Requirements
We may disclose your personal data if required by law, regulation, legal process, or governmental request, including:
- Court orders and subpoenas
- Regulatory inquiries and audits
- Law enforcement requests
- Singapore and international sanctions compliance
6.4 Business Transfers
In the event of a merger, acquisition, reorganization, or sale of assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections.
6.5 With Your Consent
We may share your data with third parties when you have provided explicit consent.
6.6 Aggregated or De-identified Data
We may share aggregated or de-identified data that cannot reasonably be used to identify you.
7. International Data Transfers
Your personal data may be transferred to and processed in countries outside Singapore. When we transfer data internationally, we ensure appropriate safeguards are in place:
- ASEAN Model Contractual Clauses (MCCs)
- Adequacy determinations where available
- Binding Corporate Rules for affiliated entities
- Contractual protections meeting PDPA standards
8. Data Security
We implement appropriate technical and organizational measures to protect your personal data:
Technical Measures:
- Encryption of data in transit (TLS/SSL) and at rest
- Secure authentication protocols
- Regular security audits and penetration testing
- Intrusion detection and prevention systems
- Access controls and role-based permissions
Organizational Measures:
- Staff training on data protection
- Data access limited to authorized personnel
- Incident response procedures
- Regular security reviews
Blockchain Security:
- Non-custodial architecture (you control your keys)
- Smart contract audits
- Secure wallet connection protocols
Despite our security measures, no method of transmission or storage is 100% secure. We cannot guarantee absolute security of your data.
9. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected:
| Data Category | Retention Period |
|---|---|
| Wallet address | Duration of Platform use + 7 years |
| Transaction records | 7 years (regulatory requirement) |
| KYC/AML documents | 5 years after account closure |
| Support communications | 3 years |
| Usage analytics | 2 years (anonymized thereafter) |
| Marketing preferences | Until consent withdrawn |
After the retention period, data is securely deleted or anonymized.
Blockchain Data: Transaction records on the Canton blockchain are permanent and immutable. We cannot delete on-chain data.
10. Your Rights
Under the PDPA and applicable data protection laws, you have the following rights:
10.1 Right of Access
You may request access to your personal data we hold. We will respond within 30 days.
10.2 Right of Correction
You may request correction of inaccurate or incomplete personal data.
10.3 Right to Withdraw Consent
You may withdraw your consent for data processing at any time, subject to legal and contractual restrictions. Note that withdrawing consent may affect your ability to use the Platform.
10.4 Right to Data Portability
You may request a copy of your personal data in a commonly used, machine-readable format.
10.5 Right to Deletion
You may request deletion of your personal data, subject to:
- Legal retention requirements
- Ongoing contractual obligations
- Legitimate business interests
- On-chain data cannot be deleted
10.6 Right to Object
You may object to processing based on legitimate interests. We will cease processing unless we have compelling legitimate grounds.
10.7 Exercising Your Rights
To exercise any of these rights, contact our DPO:
Email: [email protected]
Subject: "Data Subject Request - [Right Requested]"
We may require verification of your identity before processing requests.
11. Cookies and Tracking Technologies
We use cookies and similar tracking technologies. For detailed information, please see our Cookie Policy.
11.1 Types of Cookies
| Cookie Type | Purpose | Duration |
|---|---|---|
| Essential | Platform functionality | Session |
| Analytics | Usage analysis | Up to 2 years |
| Preference | User settings | Up to 1 year |
11.2 Managing Cookies
You can control cookies through your browser settings. Note that disabling essential cookies may impair Platform functionality.
12. Children's Privacy
The Platform is not intended for users under 18 years of age. We do not knowingly collect personal data from children. If we learn that we have collected data from a child, we will delete it promptly.
13. Third-Party Links
The Platform may contain links to third-party websites or services. We are not responsible for the privacy practices of third parties. We encourage you to review their privacy policies.
14. Changes to This Policy
We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last Updated" date. Material changes will be notified through the Platform or via email.
Your continued use of the Platform after changes constitutes acceptance of the updated Privacy Policy.
15. Do Not Track
Some browsers transmit "Do Not Track" signals. The Platform does not currently respond to these signals, as there is no industry standard for compliance.
16. California Privacy Rights (CCPA)
If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA). However, the Platform is not available to users in the United States.
17. European Privacy Rights (GDPR)
If you are located in the European Economic Area, you may have additional rights under the General Data Protection Regulation (GDPR). However, the Platform is not available to users in the EEA.
18. Complaints
If you believe we have violated your privacy rights, you may:
- Contact our DPO at [email protected]
- File a complaint with the Personal Data Protection Commission of
Singapore:
- Website: https://www.pdpc.gov.sg
- Email: [email protected]
19. Contact Us
For questions about this Privacy Policy or our data practices:
Alpha DNA Private Limited
Email: [email protected]
DPO Email: [email protected]
Website: https://unhedged.gg
20. Consent
By using the Platform, you consent to:
- The collection, use, and disclosure of your personal data as described in this Privacy Policy
- The transfer of your data to third parties and other jurisdictions as described herein
- The use of cookies and tracking technologies as described in our Cookie Policy
If you do not consent to any of the above, please do not use the Platform.
Last Updated: January 1, 2026
© 2025-2026 Alpha DNA Private Limited. All rights reserved.