• Platform Agreement
• Privacy Policy
• Acceptable Use Policy
• Disclosures

Last updated: November 6, 2025

1. IMPORTANT TERMS.

1.1. This Platform Agreement (the “Agreement”) is between Arta Tech Pte. Ltd. (“Arta,” “we,” “our,” or “us”) and you (“Customer,” “you,” or “your”) and governs your use of our website, mobile applications, and related services, including AI agents, portfolio tools, and data insights (collectively, the “Service”).
1.2. By using the Service, you agree to this Agreement, our Acceptable Use Policy, and our Privacy Policy (together, the “Terms”). If there is a conflict between this Agreement and any other component of the Terms, this Agreement controls.
1.3. We may update the Terms by posting updated Terms on our website or in the Service. Updates become effective when posted unless otherwise stated. For material updates (other than those required by law or related to new functionality or preview features), Arta will provide at least 15 days’ advance notice. Your continued use of the Service after an update becomes effective constitutes acceptance of the update.
1.4. The Service is a research and information tool; its output is AI-generated and may contain errors or be incomplete. Arta is not a fiduciary and does not provide investment, financial, or tax advice. All information and tools are for informational and educational purposes only and are not a substitute for professional advice. You are solely responsible for verifying and relying upon any output.

2. DEFINITIONS.

“Acceptable Use Policy” means Arta’s policy governing permitted use of the Service.
“Account” means your registered profile for accessing and using the Service.
“Advisor” means a licensed financial professional or organization that uses the Service to analyze or manage client data.
“Aggregated Data” means data that results from the combination or aggregation of Customer Data with other data so that it no longer identifies, and cannot reasonably be used to identify, an individual or Customer.
“AI Output” means the data, analysis, or text generated by the Service in response to your Input.
“Client Data” means any personal, financial, or other information relating to a client of an Advisor that is uploaded, transmitted, or otherwise made available through the Service by or on behalf of such Advisor. Client Data is a subset of Customer Data. Advisors are the data controllers of their Client Data, and Arta processes such data solely as a data processor or service provider in accordance with this Agreement and applicable law.
“Confidential Information” means non-public information disclosed by a party that is identified as confidential or should reasonably be understood to be confidential.
“Customer Data” means any information or content that you upload or provide to the Service, including Inputs, Client Data, and any personal or financial information.
“Documentation” means technical or other documentation provided by Arta regarding use of the Service.
“Effective Date” means the date you first use the Service.
“Embargoed Countries” means countries subject to U.S. and Singapore embargoes or sanctions or otherwise prohibited by applicable export laws.
“Feedback” means suggestions, enhancement requests, recommendations, corrections, or other feedback you provide relating to the Service.
“Input” means data, content, or instructions you provide to the Service.
“Output” means the AI-generated response, data, or results produced by the Service in response to Input.
“Personal Data” means any information relating to an identified or identifiable natural person.
“Privacy Policy” means Arta’s privacy statement as updated from time to time.
“Service” means Arta’s software offering available via https://arta.ai and related interfaces.
“Systems Data” means technical logs, diagnostics, and usage analytics collected by Arta to operate, secure, and improve the Service.
“Usage Data” means aggregated or anonymized data derived from your interactions with the Service that cannot reasonably identify you.
“You” or “Customer” means the individual or organization using the Service.

3. USAGE.

3.1. Access Rights. Subject to your compliance with the Terms, Arta grants you a limited, non-exclusive, non-transferable right to access and use the Service for your personal or advisory purposes in accordance with the Documentation.
3.2. Credentials. Access credentials are personal to you and may not be shared. You will take reasonable steps to prevent unauthorized use and promptly notify Arta of any suspected unauthorized access.
3.3. Restrictions. You may not (i) reverse engineer, decompile, or attempt to discover the source code or models; (ii) use the Service to build a competitive product or service; (iii) publicly benchmark or performance test without written consent; (iv) use automated means to scrape data except via approved APIs or tools; or (v) use the Service for illegal, harmful, or fraudulent purposes.
3.4. Feedback. You grant Arta a royalty-free, perpetual license to use Feedback to develop, improve, support, and operate the Service, provided Arta will not use Feedback to identify you or disclose your Confidential Information.

4. INPUTS, OUTPUTS, AND DATA HANDLING.

4.1. Ownership. As between you and Arta, you retain ownership of your Inputs, Customer Data, Client Data, and any AI Outputs generated for you. You grant Arta a limited, non-exclusive, worldwide license to process your Inputs, Customer Data, Client Data, and AI Outputs to: (a) provide and maintain the Service; (b) prevent or address technical or security issues; (c) develop, train, and improve Arta’s proprietary AI agents, orchestration layers, and agentic systems; (d) provide personalized features, insights, and notifications (such as alerts based on your portfolio holdings); and (e) analyze de-identified, Aggregated Data for analytics.
4.2. Advisor Accounts. For Advisor accounts, you represent and warrant that you have obtained explicit, verifiable consent from your clients to upload, process, or analyze their data through the Service. With respect to Client Data, you are the data controller, and Arta acts solely as a data processor, processing such data only on your documented instructions. Arta will not use or disclose Client Data except as necessary to provide the Service or as required by law. Advisors may request deletion of Client Data upon account termination.
4.3. Treatment of Inputs. Inputs may include personal, financial, or portfolio data you upload or enter into the Service. Arta processes Inputs to generate Outputs and deliver requested functionality. By using the Service, you provide Arta explicit consent to use your Inputs (such as portfolio data) to train and improve Arta’s proprietary agentic systems and orchestration layers to create derivative works that enhance your product experience. Your Inputs will not be used to train third-party foundational models.
4.4. Treatment of AI Outputs. AI Outputs are generated automatically and may include inaccuracies or omissions. You must independently verify all Outputs before relying on them. Arta provides Outputs on an “as is” basis and makes no warranties regarding their accuracy or completeness. Arta has no liability for losses arising from reliance on any AI Output.
4.5. Systems and Usage Data. Arta collects Systems Data (such as device identifiers, logs, and performance metrics) and Usage Data (aggregated, anonymized analytics) to maintain, secure, and enhance the Service. Systems and Usage Data will not be combined with identifiable Customer Data. Such data may be retained indefinitely for analytical and security purposes.
4.6. Privacy Protections. Arta applies commercially reasonable safeguards to protect Customer Data, Client Data, and Personal Data, including encryption in transit and at rest where applicable. Arta will not sell, rent, or disclose your data for third-party marketing. Processing is governed by the Privacy Policy and applicable law. Cross-border data transfers, if any, will comply with applicable privacy laws, including the PDPA where applicable.
4.7. Retention and Deletion. Arta retains Customer Data and Client Data only for as long as necessary to provide the Service or comply with legal obligations. Upon request, Arta will delete or anonymize your personal data unless continued retention is legally required. Aggregated Data may be retained indefinitely for analytics and improvement purposes.
4.8. Data Rights and Requests. You may request access to, correction of, or deletion of your personal data processed by Arta. Advisors may request deletion of Client Data. Arta will respond in accordance with applicable privacy laws. Certain data may be retained as required for fraud prevention, security, or legal compliance.
4.9. Third-Party Model Providers. To provide certain features, Arta’s orchestration layer may process Inputs using third-party AI model providers, who act as Arta’s sub-processors. Arta evaluates these sub-processors to ensure they meet robust security, confidentiality, and privacy standards, including compliance with applicable laws such as Singapore's PDPA. Arta maintains enterprise agreements with these sub-processors that contractually prohibit them from using your Inputs, Customer Data, or AI Outputs to train their models or for any purpose other than providing the contracted service to Arta.
4.10. Use of Outputs. You may store, display, or share AI Outputs for personal or client use, subject to these Terms and applicable law. You may not represent Outputs as factual, guaranteed, or endorsed by Arta without written permission.

5. FEES AND PAYMENTS.

5.1. Subscription and Billing. If the Service offers paid features, subscription pricing and billing terms are disclosed at the point of purchase (for example, within the app, or Arta’s pricing page). By starting a subscription, you authorize Arta (or its payment processor) to charge the subscription amount and applicable taxes to your chosen payment method on a recurring basis until you cancel.
5.1.1. Changes to Fees and Tiers. Arta reserves the right to change the subscription fees, maximum credit amounts, or other terms for its payment tiers at any time. For existing subscribers, any such changes will take effect at the start of your next billing cycle.
5.2. Taxes. Fees are exclusive of taxes unless stated otherwise. You are responsible for any applicable taxes, duties, or similar governmental assessments, excluding taxes based on Arta’s income.
5.3. Disputes and Late Payments. If you believe a charge is incorrect, contact billing@arta.ai within 30 days. Undisputed past-due amounts may result in suspension of access after notice.
5.4. Cancellation and Refunds. You may cancel your subscription at any time through your account settings or the applicable app store settings. When you cancel, your subscription will remain active until the end of the current billing period, and the plan will automatically adjust from the next month. Payments already made for the current period are non-refundable unless otherwise required by law.

6. TERM AND TERMINATION.

6.1. Term. This Agreement takes effect as of the Effective Date and remains in effect until terminated by you or by Arta as permitted herein.
6.2. Suspension and Termination. We may suspend or terminate your access for violations of the Terms, for security reasons, or where required by law. Upon termination, your right to use the Service ends.

7. INDEMNIFICATION.

You will defend, indemnify, and hold harmless Arta and its affiliates from and against any third-party claim arising from or relating to (a) your Inputs, Customer Data, or Client Data; (b) your violation of law or these Terms; or (c) your gross negligence or willful misconduct, including reasonable attorneys’ fees and costs.

8. WARRANTY AND DISCLAIMER.

You warrant that you have the necessary rights in any Customer Data, Client Data, or Input you upload and that your use of the Service complies with applicable laws. EXCEPT AS EXPRESSLY STATED, THE SERVICE AND ANY OUTPUTS ARE PROVIDED “AS IS” AND “AS AVAILABLE.” ARTA DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. ARTA DOES NOT WARRANT THAT THE SERVICE OR OUTPUTS WILL BE ACCURATE, COMPLETE, OR ERROR-FREE.

9. LIMITATIONS ON LIABILITY.

9.1. No Consequential Damages. To the maximum extent permitted by law, neither party will be liable for any indirect, incidental, special, exemplary, punitive, or consequential damages, including lost profits or revenue, arising out of or relating to this Agreement or the Service.
9.2. Liability Cap. Except for liabilities that cannot be limited by law, each party’s total aggregate liability arising out of or relating to this Agreement will not exceed the amounts you paid to Arta for the Service, if any, in the 12 months preceding the event giving rise to the claim.
9.3. AI Output Liability. Arta shall have no liability for actions you take based on AI Outputs or for any damages arising from reliance on such Outputs. You acknowledge that AI-generated information may be inaccurate or incomplete.

10. CONFIDENTIALITY; GOVERNING LAW; DISPUTE RESOLUTION; GENERAL.

10.1. Confidentiality. Each party, as Receiving Party, will use the same degree of care it uses to protect its own confidential information (but not less than reasonable care) to protect the other party’s Confidential Information, and will use it only for purposes of this Agreement. If legally compelled to disclose, the Receiving Party will (where legally permitted) provide advance notice to allow the Disclosing Party to seek protective treatment.
10.2. Governing Law; Arbitration. This Agreement is governed by the laws of Singapore. Any dispute will be resolved by binding arbitration in Singapore, in English, under the SIAC Rules. Judgment on the award may be entered in any court of competent jurisdiction. Nothing in this section prevents either party from seeking interim injunctive relief in a court of competent jurisdiction.
10.3. Assignment. You may not assign this Agreement without our consent. Arta may assign this Agreement to an affiliate or in connection with a merger, acquisition, or sale of assets.
10.4. Export Control. You will comply with all applicable export and import laws and regulations, including restrictions related to Embargoed Countries and restricted party lists.
10.5. Force Majeure. Neither party is liable for delays or failures due to causes beyond its reasonable control, excluding payment obligations.
10.6. Notices. Notices must be in writing and sent to legal@arta.ai and to the email associated with your account (for you).
10.7. Entire Agreement; Waiver; Severability. The Terms constitute the entire agreement between the parties regarding the Service and supersede prior or contemporaneous agreements on the subject matter. No waiver is effective unless in writing. If any provision is unenforceable, it will be limited to the minimum extent necessary so the remainder remains in effect.

Last Updated: November 6, 2025

This Privacy Policy explains how Arta Tech Pte. Ltd. (collectively, “Arta,” “we,” “us,” or “our”) collects, uses, discloses, and otherwise processes personal data in connection with its platform and related mobile applications (collectively, the “Services”). Arta is an organization under the Singapore Personal Data Protection Act 2012 (‘PDPA’). We collect, use, and disclose personal data in compliance with the PDPA and its subsidiary legislations.

This Policy applies to all users of the Services. If you have any questions or complaints about this Policy, please contact our DPO at privacy@arta.ai.

Click on the links below to jump to specific sections:

• INFORMATION WE COLLECT AND HOW WE COLLECT IT
• INFORMATION WE COLLECT AUTOMATICALLY
• INFORMATION WE COLLECT FROM OTHER SOURCES
• HOW WE USE YOUR INFORMATION
• DISCLOSURES OF INFORMATION
• THIRD-PARTY TRACKING AND ONLINE ADVERTISING
• YOUR CONTROLS
• ADDITIONAL US STATE PRIVACY RIGHTS
• DATA RETENTION
• DATA SECURITY
• DATA BREACHES
• CHILDREN
• CHANGES TO THIS POLICY
• HOW TO CONTACT US

1. INFORMATION WE COLLECT AND HOW WE COLLECT IT

We collect information you provide when you use our Services or otherwise communicate with us:

• Identity Data, such as your name, date of birth, marital status, social security number, photos of your face and government-issued identification documents, and other data on government-issued identification documents;
• Contact Data, such as your email address, mailing address, and telephone number;
• Financial Data, such as your investment holdings, which you may enter manually, and financial statements or other documents (e.g., PDFs, CSVs, screenshots) that you choose to upload for parsing and analysis. Information on these statements may include bank account details.
• Payment Data (collected by our third-party payment processor) and related transaction information
• Profile Data, such as your username and password, your knowledge assessment results, your interests, preferences, feedback, and survey responses;
• Stored Content, such as photos and/or documents stored in your mobile and/or computer device or email accounts. We only collect this information with your permission. You may withdraw your consent for such access at any time by adjusting your device or account settings.;
• Other Information You Provide: We collect additional personal data that you choose to provide to us, such as via focus groups, survey responses, contests, sweepstakes, customer support, or other means.

We will notify you of the purposes for which your personal data is collected, used, or disclosed before or at the time of collection, and obtain your consent unless an exception under the PDPA applies. For example, when you sign up or upload documents, we will notify you in-app or on the relevant webpage of the purposes for which we require such data.

1. INFORMATION WE COLLECT AUTOMATICALLY

We collect certain information about you automatically when you use our Services:

• Usage and Technical Information: We collect information about your activity on our Services, which includes device identifiers (like IP address), device type, and browser information.
• Information Collected Through Tracking Technologies: We and our service providers use technologies, including cookies, to automatically collect certain types of usage and device information when you use our Services. This information is used for fraud prevention, debugging, and basic analytics.
• Location and Device Data: We may collect the GPS location of your mobile device in accordance with your device permissions. You can stop the collection of this precise location information at any time (review “Your Controls” section for details). Google uses technologies to approximate your location, including IP address (review Google’s Privacy Policy located at https://policies.google.com/privacy to learn more about how they process this information). We also approximate your location by your IP address.
• Information Collected Through Tracking Technologies: We and our service providers also use technologies, including cookies and web beacons and software development kits (“SDKs”), to automatically collect certain types of usage and device information when you use our Services or interact with our emails. For example, the information collected through these technologies includes your IP address, browser type, internet service provider, platform type, device type, operating system, date and time stamp, a unique device or account ID, usage information, and other similar information. For information about how to disable cookies, review “Your Controls” section for details.
• Inferred Data: We may also infer information about you such as your gender, based on your first name.

1. INFORMATION WE COLLECT FROM OTHER SOURCES

We also obtain information about you from other sources:

• Third-Party Authentication Services: We collect Account and Identity Information passed to us from our third-party login and authentication service provider, which includes information such as your email address, your first and last name.
• Connected Services: If you link, connect, or log in to your Arta AI Account with a third-party service (e.g., Google, Apple), the third-party service may send us information such as your profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
• Publicly Available Data: This may include contact information, your interactions with our social media platforms, and other information from publicly available sources, such as public websites.
• Advertising Data: We collect information in connection with our ad campaigns that surface on other platforms, such as the ads you click on and other interactions with our ads.

1. HOW WE USE YOUR INFORMATION

We use the information we collect for purposes described below or as otherwise described to you at the point of collection:

• Maintain and provide the Services, including to create and manage your account, tag your data to your account, display your identity in the UI, parse and analyze your financial documents, display your portfolio holdings, and allow the Sidekick Agent to generate insights;
• Send you transactional or relationship information, administrative messages and email communications, or communications about offers you may be interested in such as product announcements, partner offerings, surveys, contests or sweepstakes, personalized advertising, and events or announcements;
• Customize content or ads;
• Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
• Monitor and improve our Services, including analyzing usage, debugging user issues, and for quality and evaluation purposes;
• Help protect the safety and security of our Services, business, and users, such as to investigate and help prevent fraud;
• Protect or exercise our legal rights or defend against legal claims, including to enforce and carry out contracts and agreements;
• Comply with applicable laws and legal obligations; and
• Any other lawful purpose for which we obtain your consent.

We may process your personal data for these purposes for both mandatory and optional reasons. We will not process your personal data for any additional purposes that are incompatible with the original purpose for which it was collected unless permitted by applicable law.

Our legal bases for processing your information as described in this Policy are as follows:

• Contractual Necessity. Where use of your information is necessary to perform our obligations under a contract or commitment to you. For example, to:
  • Provide the Services you’ve requested from us;
  • Comply with our applicable agreements; and
  • Make and receive payments.
• Legitimate Interests. Where use of your information furthers our legitimate interests or the legitimate interests of others. For example, to:
  • Operate our business and our Services;
  • Defend our legal rights;
  • Provide safety and security for our Services;
  • Reduce abuse and prevent fraud in connection with the use of our Services; and
  • Develop and improve the Services.
• Legal Obligation. Where we use your information to comply with applicable legal obligations. For example, to:
• Keep track of usage of our Services for tax, accounting, and auditing purposes; and
• Respond to compulsory government requests.
• Consent. Where you have consented to our processing of your information for a particular purpose in jurisdictions where consent is required. For example, depending on your jurisdiction, to:
• Send you marketing communications
• Collect and process information through cookies and similar tools as discussed immediately below.
• We rely on your consent or deemed consent where appropriate, or other exceptions permitted under the PDPA (such as situations necessary to respond to emergencies, comply with legal obligations, or for evaluative purposes). If any purpose for using your personal data is not stated at the time of collection, we will notify you and obtain your further consent before proceeding.

6. DISCLOSURES OF INFORMATION

We are committed to maintaining your trust, and we want you to understand when and with whom we share information about you. We share information about you in the instances described below:

• Service Providers. We may engage third parties to act as our service providers and perform certain tasks on our behalf, such as processing or storing data, including personal data, in connection with your use of our services and delivering products to customers. They include:
  • Hosting, technology and communication providers.
  • Security and fraud prevention consultants.
  • Support and customer service vendors.
  • Product fulfillment and delivery providers.
  • Audio transcription providers and processors.
  • Payment processors.
• Marketing Partners: We disclose information about you to third-party advertising and analytics services, as described in Third-Party Tracking and Online Advertising.
• Substantial corporate transactions: We may disclose information about you in connection with a substantial corporate transaction, a merger, consolidation, reorganization, financing, change in control or acquisition of all or a portion of our business by a third party, or in the unlikely event of a bankruptcy or similar proceeding.
• Legal purposes: We disclose information about you if we believe that disclosure is in accordance with, or required by, any applicable law or legal process or to protect and defend the rights, interests, safety, and security of Arta, our users, or the public.
• With your consent: We disclose information about you for any other purposes disclosed to you with your consent.

We may also use and disclose information with others in an aggregated or otherwise de-identified form that does not reasonably identify you.

• Legal purposes. We disclose information about you if we believe that disclosure is in accordance with, or required by, any applicable law or legal process.
• Corporate transactions. We may share information about you in connection with a corporate transaction, such as a merger or acquisition.
• Arta Affiliates. Where appropriate, we may share information about you with other companies owned or controlled by Arta.

Where we transfer your personal data outside Singapore, we will ensure that the recipient is bound by legally enforceable obligations to provide a standard of protection comparable to the PDPA. This includes agreements with our service providers located overseas, such as cloud hosting or analytics vendors.

7. THIRD-PARTY DATA COLLECTION AND ONLINE ADVERTISING

We and our service providers may use cookies, pixels, device identifiers, and similar technologies to collect information from and about your use of our websites, apps, and other online services or interactions, including when we use third-party advertising and analytics services to better understand your online activity and serve you targeted advertisements. The information collected includes your IP address, web browser, mobile network information, pages viewed, time spent, links clicked, conversion information, and other internet and electronic activity information and device information. We and our third-party partners use this information to, among other things, analyze and track data, determine the popularity of content, and deliver advertisements targeted to your interests on our website and other platforms, as well as to provide advertising-related services to us such as reporting, attribution, analytics, and market research.

Information collected and processed by these partners is subject to those partners’ own policies. For example, we may use Google Analytics for the purposes described in this section. Information collected and processed by Google is subject to Google’s policies, including their Privacy Policy. You can review Google’s Privacy Policy linked here: https://policies.google.com/privacy, as well as the “How Google uses information from sites or apps that use our services” article linked here: https://policies.google.com/technologies/partner-sites, for information about how Google processes the information it collects.

The information that is collected may be collected over time and combined with information collected on different websites and online services and across your devices, including to deliver targeted advertising to you, both on and off our websites. For more information about targeted advertising, including to learn about options for opting out of having your web browsing information used for targeted advertising purposes, please visit www.aboutads.info/choices. You should also review your mobile device settings and controls for features that allow you to opt out or opt in to having certain information collected for behavioral advertising purposes.

You may also have additional rights under state laws. For more information, review Additional US State Privacy Rights.

8. YOUR CONTROLS

We provide you with the following controls regarding your information.

• How to control your communications preferences. You can stop receiving promotional emails from us by clicking the “unsubscribe” link in those emails. We may still send you service-related or other non-promotional communications, such as account notifications, receipts, security notices and other transactional or relationship messages.
• Access to your device data. You may disconnect our mobile app’s access to certain stored device information through your device’s settings. For instance, you can withdraw permission for the app to access your photo gallery.
• Affiliate sharing opt out. In some cases, you can limit sharing between Arta affiliates. Please see the privacy notice of each affiliate for more details. If you want to exercise this right, please contact us at privacy@arta.ai.
• Cookie controls. Many web browsers are set to accept cookies and similar tracking technologies by default. If you prefer, you can set your browser to delete or reject these technologies. If you choose to delete or reject these technologies, this could affect certain features of our Services. If you use a different device, change browsers, or delete the opt-out cookies that contain your preferences, you may need to perform the opt-out task again.

Under the PDPA, you have the right to: (a) access your personal data that we hold; (b) request correction of any inaccuracy or omission; (c) withdraw consent for our collection, use, or disclosure of your personal data; and we will respond to your request within a reasonable time and in accordance with PDPA requirements.To exercise these rights, please contact our Data Protection Officer via the contact details provided below.

9. ADDITIONAL US STATE PRIVACY RIGHTS

This section provides additional details about personal data and the rights afforded to residents of certain US states under applicable state laws (collectively, “State Privacy Laws”). This section applies only to users residing in certain U.S. states and does not apply to individuals in Singapore.

Please note that these State Privacy Laws do not apply to all personal data that we collect and process. For example, they do not apply where personal data is governed instead by federal financial privacy laws, such as the Gramm-Leach-Bliley Act (“GLBA”).

Subject to certain limitations and exceptions, these State Privacy Laws provide their residents with certain rights. Depending on the state in which you are a resident and your relationship to us, and subject to the limitations provided in these State Privacy Laws, you may have the right to:

• Confirm whether Arta processes your personal data and obtain information about our processing activities;
• Correct inaccurate personal data;
• Receive a copy of or details (in a readily usable format) about the categories and specific elements of personal data we collect;
• Delete your personal data;
• Opt out of any “sales,” “sharing,” “targeted advertising,” or “profiling” for certain consequential decisions (as these terms are defined in these State Privacy Laws); and
• Not be discriminated against for exercising these rights.

The categories of personal data we collect (and have processed over the past 12 months) include: identifiers (such as IP address), internet or other electronic network activity information (such as website usage and engagement with promotional messages and ads), inferences, and as otherwise described in “Information We Collect And How We Collect It”. We do not knowingly collect information that is considered “sensitive” under State Privacy Laws and we do not use or disclose sensitive personal data for the purpose of inferring characteristics about you.

For more details about the information we collect (including the categories of sources of this information) as well as the purposes for processing, review the “Information We Collect And How We Collect It” section.

We disclose this information with the categories of third parties described in Disclosures of Information. The following bulletpoints describe for each applicable category of personal data collected that is subject to these State Privacy Laws, the categories of third parties to which such information has been “sold” or “shared” (i.e., shared for targeted advertising) over the past 12 months.

• Category of Personal Data
  • Identifiers, Internet or other electronic network activity information, Inferences
• Categories of Third Parties
  • Advertising and marketing partners, social networks

We do not knowingly “sell” or “share” personal data about individuals under the age of 16.

How to Exercise Your Rights: To exercise these rights, please contact us at privacy@arta.ai. We may verify the request by asking you to provide information that matches information we have on file about you.

10. DATA RETENTION

Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which we originally collected it and for other business purposes explained in this Privacy Policy. When personal data is no longer required, we will anonymize or securely dispose of it in accordance with our data retention policy.

11. DATA SECURITY

We implement reasonable administrative, physical, and technical measures to protect your personal data against unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks. Access to personal data is limited to personnel who require it to perform their duties. Where personal data is processed by third-party service providers, we require such parties to implement comparable security measures and to process personal data only for our authorized purposes.

12. DATA BREACHES

If we discover a data breach that results in, or is likely to result in, significant harm to individuals, or where the scale of the breach meets PDPA thresholds, we will notify the PDPC and affected individuals as required under the PDPA.

13. CHILDREN

We do not knowingly collect or solicit any information from anyone under the age of 13. If you reasonably believe that we might have information from a child under 13, please contact us at privacy@arta.ai. For individuals below 13 in Singapore, consent must be provided by a parent or legal guardian before we collect, use, or disclose any personal data.

14. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy will evolve with time, and when we update it, we will revise the "Effective Date" above and post the new Privacy Policy and, in some cases where changes materially affect how we handle your personal data, we provide additional notice (such as adding a statement to our website or sending you a notification).

15. HOW TO CONTACT US

If you have questions about this Privacy Policy, contact our Data Protection Officer (DPO) in Singapore at privacy@arta.ai, or by postal mail at Arta Tech Pte. Ltd., 21 Collyer Quay, Singapore. If you have a complaint regarding our handling of your personal data, please contact our DPO. We will acknowledge your complaint within 5 business days and aim to resolve it within 30 calendar days.

Last Updated: November 6, 2025

We aim for our tools, including Sidekick, to be used safely and responsibly, while maximizing your control over how you use them. In building our Usage Policy, we keep a few important principles in mind.

• We empower users to innovate. We build tools that maximize helpfulness and freedom for the wealth management experience, while ensuring safety. This Usage Policy is one way we set clear expectations within a broader safety ecosystem.
• Responsible use is a shared priority. We assume the best of our users. Our terms and policies set a reasonable bar for acceptable use. These rules are no substitute for any legal requirements, professional duties, or ethical obligations that influence how people use our tools. Breaking or circumventing our rules and safeguards may mean you lose access to our systems.
• We build with safety first. We monitor and enforce policies with privacy safeguards in place. We publish what our systems can and can’t do and provide a simple way to report misuse.
• We update as we learn. People are using our systems in new ways every day, and we update our rules to ensure they are not overly restrictive and to better protect our users.

Your use of Arta AI services, including Sidekick, must follow this Usage Policy:

1. Compliance with Financial Services Regulations

This is our most important policy. Sidekick is an analytical and diagnostic tool, not a licensed financial advisor or fund manager. Its purpose is to provide data analysis, tools and reporting to facilitate a user's wealth management experience.

How you may use Sidekick depends on whether you are a licensed financial professional.

A. For All Users:

If you are not a licensed financial advisor, fund manager, or other regulated financial professional, you must not use Sidekick for any regulated activity for others. This includes:

• Providing financial advice, investment recommendations, or portfolio management services to any other person (whether for a fee or not).
• Representing, either explicitly or implicitly, that Sidekick is providing regulated financial advice.
• Using Sidekick's output as a direct "buy," "sell," or "hold" recommendation without seeking independent advice from a qualified professional or making an independent decision yourself understanding the full risks involved with using the output.Do not use Sidekick's output as a direct "buy," "sell," or "hold" recommendation. Always seek independent advice from a qualified professional or make your own informed decision, understanding the full risks associated with using the output.

B. For Licensed Financial Professionals:

If you are a licensed financial professional (e.g., a financial advisor, registered fund manager), you may use Sidekick as an analytical tool to support your regulated activities, subject to the following conditions:

• Licensure: You have a license to provide regulated activities, for example, including financial advisory services.
• Your responsibility: You remain fully and solely responsible for all advice, recommendations, and investment decisions.
• Independent Professional Judgment: You must apply your own independent, professional judgment to review, validate, and, where appropriate, modify any output from Sidekick before it is used as the basis for any advice or client communication.
• No Automated Decision-Making: You must not use Sidekick to make fully automated, high-stakes decisions for a client (e.g., executing trades) without your direct review and final approval.
• Compliance: You must ensure that your use of Sidekick complies with all professional, ethical, and regulatory obligations applicable to you and your license.

2. Protect People

Everyone has a right to safety and security. You cannot use our services for:

• Threats, intimidation, harassment, or defamation.
• Promotion or facilitation of suicide, self-harm, or disordered eating.
• Terrorism, hate speech, or the promotion of violence.
• Illicit activities, fraud, or the promotion of illegal goods and services.
• Destruction, compromise, or breach of another’s system or property, including malicious or abusive cyber activity (e.g., malware, hacking, phishing).

3. Respect Privacy

People are entitled to privacy. You cannot use our services for:

• Attempting to compromise the privacy of others, including monitoring, profiling, or distributing individuals’ private or sensitive information without their authorization.
• Distributing an individual’s non-public financial information without their consent.
• Attempting to de-anonymize or re-identify individuals from aggregated or anonymized data.

4. Maintain Platform Integrity

To ensure the safety and reliability of our service, you must not use our services for:

• Deceit, fraud, scams, spam, or impersonation of any person or entity.
• Attempting to circumvent our safeguards, safety filters, or "jailbreak" the tool.
• Automation of high-stakes decisions in sensitive areas (e.g., legal, financial) without human review.

Arta AI is developed by Arta Tech Pte. Ltd., a Singapore-based technology company and affiliate of Arta Finance Inc. (“Arta”). Arta AI is a software platform designed to support individuals, including wealth managers, financial advisors, and institutions with AI-powered tools for portfolio analysis, client engagement, and research automation.

Arta AI does not provide investment advice, solicitation, or recommendations. Arta Tech Pte. Ltd. is not licensed by the Monetary Authority of Singapore (MAS) or any other regulatory body to offer regulated financial advisory, fund management, or capital markets services. Therefore, users should not solely depend on Arta AI or its outputs for investment decisions. The platform serves to enhance, not substitute, professional judgment; users are advised to consult licensed financial professionals before undertaking any investment actions.

All content, insights, and analytics generated by Arta AI are provided for informational and educational purposes only. The platform’s outputs are based on models, data inputs, and user-provided information, which may not account for your specific investment objectives, financial situation, or needs. Investing involves risk, including the possible loss of principal. Past performance is not indicative of future results. AI-driven analyses, including stress tests and Monte Carlo simulations, are probabilistic tools that cannot predict actual market outcomes.

All trademarks, trade names, logos, and software associated with Arta AI are the property of Arta Tech Pte. Ltd. or its affiliates.