Privacy Policy

Introduction

This Privacy Policy (“Policy”) describes how Positioned Pte. Ltd. (“Positioned,” “we,” “us,” or “our”), a company incorporated in Singapore, collects, uses, discloses, and otherwise processes your personal data when you access or use our website, mobile applications, and related services (collectively, the “Services”).

By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by this Policy. If you do not agree with any part of this Policy, you must immediately discontinue use of our Services. This Policy should be read in conjunction with our Terms of Service and Disclaimer.

Important: Positioned is not a financial advisor, broker-dealer, or licensed investment professional. Our Services provide publicly available financial data and educational content only. No information on our Services constitutes financial, investment, legal, or tax advice. Please refer to our Disclaimer for further details.

While we implement commercially reasonable security measures to protect your personal data, no method of electronic transmission or storage is completely secure. You acknowledge that you provide your information at your own risk and that you are responsible for maintaining the confidentiality of your account credentials and for all activities that occur under your account.

Data Controller

For the purposes of the Personal Data Protection Act 2012 (“PDPA”) of Singapore and other applicable data protection laws, the data controller responsible for your personal data is:

1. Information We Collect

1.1 Information You Provide Directly

We may collect information that you provide directly to us, including but not limited to:

• Account Registration: When you create an account, we may collect your email address, password, and any other information you choose to provide during the registration process. We may also receive your name and profile information if you authenticate through third-party services (such as Google, Apple, or other supported providers).
• Payment Information: If you subscribe to paid services, payment information (including your name, billing address, and payment card details) may be collected and processed by our third-party payment processors. Positioned does not directly store full payment card details on its servers.
• Watchlists and Preferences: When you use our Services to create watchlists, save preferences, or input other data, we may collect and store this information to provide and improve the Services.
• Communications: When you contact us for support, feedback, or other inquiries, we collect the information you provide in your communications, including your email address and the content of your messages.
• Survey and Research Data: We may invite you to participate in voluntary surveys or research studies. Any information you choose to provide in such surveys will be collected and processed in accordance with this Policy.

1.2 Information Collected Automatically

When you use our Services, we may automatically collect certain information about your device and usage patterns, including but not limited to:

• Device Information: Device type, operating system and version, unique device identifiers, mobile network information, and device settings.
• Usage Data: Pages visited, features used, time spent on pages, search queries, click data, and navigation paths.
• Location Data: General location information derived from your IP address. We do not collect precise geolocation data unless you explicitly grant such permission.
• Log Data: IP address, browser type and version, referring/exit pages, date and time stamps, and clickstream data.
• Cookies and Similar Technologies: We use cookies, web beacons, and similar tracking technologies to collect information about your browsing activities. See Section 5 below for further details.

1.3 Information from Third-Party Sources

We may receive information about you from third-party sources, including but not limited to:

• Authentication Services: If you use third-party authentication services to create or access your account, we receive information from those providers as authorised by you and your privacy settings with those services.
• Analytics Providers: We use third-party analytics services to help us understand how users interact with our Services.
• App Store Platforms: If you download our mobile application, we may receive limited information from app store platforms regarding your download.

2. Legal Basis for Processing Your Information

We process your personal data in accordance with the PDPA and other applicable data protection laws. Our legal bases for processing include:

• Consent: Where we have obtained your explicit consent for specific processing activities, such as marketing communications.
• Contract Performance: Processing necessary to fulfil our contractual obligations to you when you use our Services.
• Legitimate Interests: Processing necessary for our legitimate business interests, such as improving our Services, preventing fraud, and ensuring security, provided such interests are not overridden by your data protection rights.
• Legal Obligations: Processing necessary to comply with our legal obligations under applicable laws and regulations, including the PDPA.

3. How We Use Your Information

We may use the information we collect for the following purposes:

• Service Delivery: To provide, maintain, and improve our Services, including personalising your experience and delivering requested features.
• Account Management: To create and manage your account, verify your identity, and process transactions.
• Communications: To send you service-related notifications, updates, security alerts, and administrative messages.
• Customer Support: To respond to your inquiries, provide customer support, and resolve technical issues.
• Analytics and Improvement: To analyse usage patterns, measure the effectiveness of our Services, and develop new features and functionality.
• Marketing: With your consent, to send you promotional materials, newsletters, and information about our Services. You may withdraw consent at any time.
• Security and Fraud Prevention: To detect, prevent, and respond to fraud, security incidents, and other potentially harmful or illegal activities.
• Legal Compliance: To comply with applicable laws, regulations, legal processes, and enforceable governmental requests.

4. How We Share Your Information

We do not sell your personal data. We may disclose your information in the following limited circumstances:

• Service Providers: We may share information with third-party service providers who perform services on our behalf, including hosting, data analytics, payment processing, customer service, and marketing assistance. These providers are contractually obligated to protect your data and use it only for the purposes we specify.
• Legal Requirements: We may disclose information if required by law, legal process, governmental request, or where we believe disclosure is necessary to protect the rights, property, or safety of Positioned Pte. Ltd., our users, or the public.
• Business Transfers: In connection with any merger, acquisition, sale of assets, financing, or transfer of all or a portion of our business, your information may be transferred to the acquiring or successor entity.
• With Your Consent: We may share information for any other purpose with your explicit consent.
• Aggregated or De-identified Data: We may share aggregated or de-identified information that cannot reasonably be used to identify you.

5. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect information about your browsing activities and to improve your experience on our Services.

5.1 Types of Cookies We Use

• Essential Cookies: Necessary for the operation of our Services, including authentication and security features. These cannot be disabled.
• Functional Cookies: Enable enhanced functionality and personalisation, such as remembering your preferences and settings.
• Analytics Cookies: Help us understand how users interact with our Services by collecting and reporting information in aggregate form.

5.2 Managing Cookies

Most web browsers allow you to control cookies through their settings. You may refuse or delete cookies; however, some features of our Services may not function properly without them. Positioned is not responsible for any loss of functionality resulting from your decision to disable cookies.

6. Data Retention and Storage

We retain your personal data only for as long as reasonably necessary to fulfil the purposes outlined in this Policy, or as required or permitted by applicable law, including the PDPA. The criteria we use to determine retention periods include: (i) the duration of your use of our Services and whether you maintain an active account; (ii) applicable legal, regulatory, or contractual obligations; and (iii) our legitimate business interests, including the establishment, exercise, or defence of legal claims.

Data Storage: Your data may be stored on servers located in Singapore and other jurisdictions where our service providers operate. When we transfer your personal data internationally, we implement appropriate safeguards in accordance with applicable data protection laws. By using our Services, you consent to the transfer of your data to jurisdictions outside your country of residence, which may have different data protection standards.

Data Deletion: Upon account deletion or expiration of the applicable retention period, we will delete or anonymise your personal data, except where retention is required by law or for legitimate business purposes (such as resolving disputes or enforcing agreements).

7. Your Rights and Choices

Subject to applicable law, including the PDPA, you may have certain rights regarding your personal data:

• Access: You may request access to the personal data we hold about you.
• Correction: You may request correction of personal data that is inaccurate or incomplete.
• Withdrawal of Consent: Where we rely on your consent to process personal data, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.
• Erasure: You may request deletion of your personal data, subject to our legal obligations and legitimate business interests.
• Data Portability: Where applicable and technically feasible, you may request to receive your personal data in a structured, commonly used format.
• Objection: You may object to certain types of processing, including processing for direct marketing purposes.

To exercise any of these rights, please contact us at privacy@positioned.app. We will respond within a reasonable timeframe in accordance with applicable law. We may require verification of your identity before processing your request. You may also update certain account information by logging into your account settings.

7.1 Marketing Communications

You may opt out of receiving promotional communications at any time by following the unsubscribe instructions in those communications or by updating your preferences in your account settings. Please note that even if you opt out of marketing communications, we may still send you non-promotional messages related to your account, transactions, or the operation of our Services.

7.2 Account Deletion

If you wish to delete your account, you may do so through your account settings or by contacting us at support@positioned.app. Please note that we may retain certain information as required by law or for legitimate business purposes, including the prevention of fraud and the resolution of disputes.

8. Security

We implement commercially reasonable technical and organisational security measures designed to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include, but are not limited to:

• Encryption of data in transit using Transport Layer Security (TLS)
• Encryption of sensitive data at rest
• Access controls and authentication mechanisms
• Periodic security assessments
• Incident response procedures

No system is completely secure. Despite our efforts, we cannot and do not guarantee the absolute security of your information. You acknowledge that there are inherent risks in transmitting information over the internet and that you bear responsibility for maintaining the security of your account credentials. Positioned Pte. Ltd. shall not be liable for any unauthorised access to your account resulting from your failure to safeguard your credentials.

9. Third-Party Links and Services

Our Services may contain links to third-party websites, services, or applications that are not owned or controlled by Positioned Pte. Ltd. We have no control over, and assume no responsibility for, the content, privacy practices, or policies of any third-party services. Your use of third-party services is at your own risk, and we encourage you to review the privacy policies of any third-party services before providing them with your personal information.

Positioned Pte. Ltd. shall not be liable for any loss or damage arising from your use of or reliance on any third-party services accessed through our Services.

10. Children's Privacy

Our Services are not directed at, and are not intended for, children under the age of 18 (or the applicable age of majority in your jurisdiction). We do not knowingly collect personal data from children. If you are under 18, you must not use our Services or provide any information to us.

If we become aware that we have inadvertently collected personal data from a child under 18, we will take reasonable steps to delete such information promptly. If you believe we may have collected information from a child, please contact us at privacy@positioned.app.

11. International Data Transfers

Positioned Pte. Ltd. is incorporated in Singapore, and your information may be transferred to, stored, and processed in Singapore or other countries where we or our service providers operate. These countries may have data protection laws that are different from, and potentially less protective than, the laws in your country of residence.

Where we transfer your personal data to jurisdictions outside of Singapore, we take reasonable steps to ensure that your information receives an adequate level of protection in accordance with applicable data protection laws. By using our Services, you expressly consent to the transfer of your information to countries outside your country of residence.

12. Jurisdiction-Specific Rights

12.1 Singapore Residents

If you are a Singapore resident, you have rights under the Personal Data Protection Act 2012 (PDPA), including the right to access and correct your personal data. You may also lodge a complaint with the Personal Data Protection Commission (PDPC) if you believe your personal data has been mishandled.

12.2 European Users (EEA, UK, Switzerland)

If you are located in the European Economic Area, United Kingdom, or Switzerland, you may have additional rights under the General Data Protection Regulation (GDPR) or equivalent legislation, including the right to lodge a complaint with your local supervisory authority, the right to data portability, and the right to object to automated decision-making.

12.3 California Residents

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, the right to request deletion, and the right to opt out of the sale of personal information. We do not sell personal information.

To exercise any jurisdiction-specific rights, please contact us at privacy@positioned.app.

13. Do Not Call

In compliance with the Singapore Do Not Call (DNC) Registry provisions under the PDPA, we will not send marketing messages to Singapore telephone numbers registered on the DNC Registry unless we have obtained your clear and unambiguous consent.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will update the “Last Updated” date at the top of this Policy. For material changes, we may also notify you by email or through a prominent notice on our Services.

Your continued use of our Services after the posting of changes constitutes your acceptance of the revised Policy. If you do not agree with the changes, you must discontinue use of our Services.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

We will endeavour to respond to your inquiry within a reasonable timeframe in accordance with applicable law.

Effective Date: February 10, 2026
Last Updated: February 10, 2026