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Effective date: 31 March 2026 · Version 1.0 Hypernova Systems 71 Fort Street, George Town, Grand Cayman, KY1-111, Cayman Islands legal@hypernova.xyz

1. Who we are

Hypernova Systems (“Hypernova”, “we”, “us”, “our”) is the operator of the Hypernova platform, accessible at hypernova.xyz and related subdomains. Our registered address is 71 Fort Street, George Town, Grand Cayman, KY1-111, Cayman Islands. We are the data controller for the personal data processed under this Privacy Policy. If you have any questions or requests relating to your personal data, please contact us at legal@hypernova.xyz.

2. Scope of this policy

This Privacy Policy applies to all users of the Hypernova platform, including visitors to our website, registered account holders, assessment participants, funded traders, and affiliate partners (together, “users”). It governs the personal data we collect when you access our website, create an account, purchase an assessment, trade on a funded account, or otherwise interact with our services. By accessing or using the platform, you acknowledge you have read and understood this policy.

3. Data we collect

3.1 Data you provide directly

When you create an account or interact with the platform, we collect:
  • Email address — used to create and manage your account, communicate service updates, and send transactional notifications.
  • Wallet address — your blockchain wallet address, used to process USDC payments and payouts on-chain.
If we introduce identity verification (KYC) in the future, we may additionally collect government-issued identification documents, full legal name, date of birth, and a live selfie for identity matching. This policy will be updated accordingly before any such collection begins, and users will be notified.

3.2 Data collected automatically

When you access the platform, our systems automatically collect:
  • IP address — logged for security monitoring, fraud detection, and to enforce restricted jurisdiction controls.
  • Device and browser data — including browser type, operating system, screen resolution, and device identifiers, collected for platform security and compatibility purposes.
  • Usage data — pages visited, features accessed, time spent on the platform, and clickstream data, collected via Google Analytics (see Section 6).
  • Session data — authentication tokens and session identifiers necessary to keep you logged in securely.

3.3 On-chain data

All payouts are executed on-chain via smart contract. On-chain transactions — including wallet addresses, transaction hashes, amounts, and timestamps — are publicly visible on the blockchain by their nature. Hypernova does not control the visibility of on-chain data.

4. How we use your data

We use the data we collect for the following purposes:
  • Service delivery — to create and manage your account, process assessment purchases, operate funded accounts, and execute payouts via smart contract.
  • Communications — to send you account confirmations, payout receipts, platform updates, and responses to your support enquiries. We do not send marketing emails without your explicit consent.
  • Security and fraud prevention — to detect and prevent unauthorised access, account sharing, prohibited trading conduct, and violations of our Rulebook.
  • Restricted jurisdiction enforcement — to identify users located in OFAC-sanctioned jurisdictions and enforce access restrictions in accordance with our Terms of Use.
  • Platform improvement — to understand how users interact with the platform and identify technical issues, using aggregated and anonymised analytics data.
  • Legal compliance — to comply with applicable laws, respond to lawful requests from government authorities, and enforce our legal agreements.
We process your personal data on the following legal bases:
  • Contractual necessity — processing your email and wallet address is necessary to provide the services you have signed up for.
  • Legitimate interests — security monitoring, fraud detection, and platform analytics are processed on the basis of our legitimate interest in operating a secure and functional platform, balanced against your privacy interests.
  • Legal obligation — where we are required to process data to comply with applicable laws or regulations.
  • Consent — where we rely on consent (for example, for marketing communications), you may withdraw consent at any time by contacting us at legal@hypernova.xyz.
Where the General Data Protection Regulation (EU) 2016/679 or the UK GDPR applies, the legal bases set out in this section apply accordingly.

6. Third-party services

6.1 Google Analytics

We use Google Analytics, a web analytics service provided by Google LLC, to collect and analyse usage data. Google Analytics uses cookies and similar tracking technologies to collect information about how users interact with the platform. This data is transmitted to and stored on Google’s servers. The data collected by Google Analytics is used in aggregated, anonymised form. We do not use Google Analytics to track individually identifiable users. You can opt out of Google Analytics data collection by installing the Google Analytics opt-out browser add-on available at tools.google.com/dlpage/gaoptout. Google’s privacy policy is available at policies.google.com/privacy.

6.2 Hyperliquid

The platform’s trading infrastructure operates via Hyperliquid. Trade execution data — including orders, positions, and settlement — is processed by Hyperliquid’s protocol. On-chain transactions are publicly visible by design.

6.3 Future service providers

We may engage additional third-party service providers in the future, including KYC verification providers, cloud hosting providers, and fraud detection services. Where any such provider processes personal data on our behalf, we will ensure appropriate data processing agreements are in place. This policy will be updated to reflect material additions.

7. Data sharing and disclosure

We do not sell, rent, or trade your personal data to third parties. We may disclose your personal data in the following circumstances:
  • Service providers — to third-party providers who process data on our behalf in order to deliver the platform (see Section 6). These providers are contractually bound to process data only as instructed by us.
  • Legal requirements — where required by law, court order, or regulatory authority, or where we believe disclosure is necessary to protect the rights, property, or safety of Hypernova, our users, or the public.
  • Business transfers — in the event of a merger, acquisition, or sale of all or part of our business, personal data may be transferred as part of that transaction. We will notify affected users in advance where reasonably practicable.
  • Sanctions enforcement — we may disclose data to relevant authorities where we identify a user as being subject to OFAC sanctions or located in a restricted jurisdiction.

8. Data retention

We retain your personal data for as long as your account is active and for a reasonable period thereafter to comply with legal obligations, resolve disputes, and enforce our agreements. Specifically:
  • Account data (email, wallet address) — retained for the duration of your account and for up to 5 years following account closure.
  • Transaction records — retained for up to 7 years to comply with applicable financial record-keeping requirements.
  • Security and fraud logs — retained for up to 2 years.
  • Analytics data — retained in anonymised, aggregated form indefinitely; individual-level data retained in accordance with Google Analytics’ data retention settings.
You may request deletion of your personal data at any time (see Section 10). We will action deletion requests subject to any overriding legal obligation to retain data.

9. Data security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. These measures include encryption of data in transit, access controls, and regular security reviews. No method of transmission over the internet or electronic storage is completely secure. While we take reasonable steps to protect your data, we cannot guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you without undue delay.

10. Your rights

Subject to applicable law, you have the following rights in relation to your personal data:
  • Access — the right to obtain a copy of the personal data we hold about you.
  • Rectification — the right to have inaccurate personal data corrected.
  • Erasure — the right to request deletion of your personal data, subject to any legal retention obligations.
  • Restriction — the right to request that we limit our processing of your personal data in certain circumstances.
  • Portability — the right to receive your personal data in a structured, machine-readable format.
  • Objection — the right to object to processing based on our legitimate interests.
To exercise any of these rights, please contact us at legal@hypernova.xyz. We will respond to all requests within 30 days. We may ask you to verify your identity before actioning a request.

11. Cookies

We use cookies and similar tracking technologies on the platform. Cookies are small text files stored on your device that help us deliver a functional and secure experience. We use the following categories of cookies:
  • Strictly necessary cookies — required for the platform to function, including session management and authentication.
  • Analytics cookies — used by Google Analytics to collect usage data as described in Section 6.
You can control cookies through your browser settings. Disabling strictly necessary cookies may impair the functionality of the platform.

12. Restricted jurisdictions

The platform is not available to individuals located in, or ordinarily resident in, OFAC-sanctioned jurisdictions. We use IP address data and other signals to detect and block access from restricted locations. Where we identify a user as being located in a restricted jurisdiction, we will terminate their account and withhold any pending payouts in accordance with our Terms of Use.

13. Children

The platform is not directed at individuals under the age of 18. We do not knowingly collect personal data from anyone under 18. If we become aware that we have collected personal data from a minor, we will delete it promptly. If you believe we have inadvertently collected data from a minor, please contact us at legal@hypernova.xyz.

14. Changes to this policy

We may update this Privacy Policy from time to time. Material changes will be communicated by email to registered users and by a prominent notice on the platform, with at least 14 days’ notice before the change takes effect. The effective date at the top of this document will be updated accordingly. Continued use of the platform after the effective date of any update constitutes acceptance of the revised policy.

15. Contact

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact: Hypernova Systems 71 Fort Street, George Town, Grand Cayman, KY1-111, Cayman Islands legal@hypernova.xyz