Privacy Policy

1. Who we are

Aarna AI Pte. Ltd., a company incorporated in Singapore ("aarnâ", "we", "us", "our"), operates this website at iyp.aarna.ai and the aarnâ India Yield Platform. We are the controller of the personal data described in this policy.

This policy explains what personal data we collect, why we collect it, who we share it with, how long we keep it and what rights you have.

2. Personal data we collect

Information you give us. When you enquire, register interest, or apply in connection with a product, we collect the information you provide. This may include your name, contact details, employer or entity details, country of residence and the substance of your enquiry.

Identity and eligibility information. Where you apply to invest, we collect the information required for identity verification, investor eligibility and regulatory screening. This may include identity documents, date of birth, nationality, address, tax identifiers, source of funds and source of wealth information, and details of beneficial ownership and control where you apply on behalf of an entity.

Blockchain information. We collect the public wallet address you connect, together with associated onchain transaction information relevant to your holding.

Technical information. When you use the Website we collect limited technical data such as IP address, device and browser type, and pages visited.

3. Why we use it, and on what basis

We use personal data to:

• verify your identity and your eligibility to access a product;
• meet anti-money-laundering, counter-terrorist-financing, sanctions-screening and know-your-customer obligations;
• operate, administer and support the platform, including processing subscriptions, redemptions and distributions;
• communicate with you and respond to enquiries;
• maintain records, manage risk, and detect and prevent fraud and financial crime;
• comply with applicable law and with requests from regulators and other competent authorities; and
• improve the Website and our services.

Depending on your jurisdiction, we rely on one or more of the following bases: performance of a contract with you or steps taken at your request before entering into one; compliance with a legal obligation; our legitimate interests in operating and protecting our business; and, where required, your consent.

4. Identity verification

Identity verification and eligibility screening are carried out with the assistance of specialist third-party providers. Those providers process your identity information on our instructions and under contract.

The outcome of verification is recorded as a cryptographic claim linked to your wallet. Personal data is not stored on any public blockchain. Onchain identity claims contain cryptographic hashes and status flags only, and cannot be used to reconstruct your identity documents or personal details.

5. Onchain information

Information recorded on a public blockchain, including wallet addresses, token balances and transaction history, is public by design, permanent and outside our control. We cannot amend or delete information once it has been recorded on a public blockchain. Please consider this before connecting a wallet you also use for other purposes.

6. Where your data is held

Platform data is hosted on infrastructure located in India, in the Mumbai region.

Some of our service providers, including identity verification, screening, communications and technology providers, may process personal data in other countries. Where personal data is transferred across borders, we put appropriate safeguards in place, including contractual protections requiring standards of protection comparable to those under applicable data protection law.

7. Who we share it with

We share personal data with:

• service providers acting on our instructions, including identity verification, screening, cloud hosting, fund administration and communications providers;
• professional advisers, including auditors, lawyers and compliance consultants;
• regulators, tax authorities, law enforcement and other competent authorities, where required or permitted by law; and
• group companies and counterparties involved in operating a product, where necessary for that purpose.

We do not sell personal data, and we do not share it for third-party advertising.

8. How long we keep it

We keep personal data for as long as necessary for the purposes described in this policy, and for as long as required to satisfy legal, regulatory and record-keeping obligations. Records relating to identity verification, transactions and regulatory reporting are typically retained for a minimum period set by applicable regulation, which may extend for several years beyond the end of your relationship with us.

Where personal data is no longer required, we delete it or anonymise it.

9. How we protect it

We maintain technical and organisational measures appropriate to the sensitivity of the data we hold. These include encryption of personal data at rest and in transit, managed key storage, role-based access controls with least-privilege scoping, additional approval requirements for sensitive operations, access logging, and secure development and dependency-scanning practices.

No system can be guaranteed to be completely secure. We keep our controls under review and maintain processes for responding to security incidents.

10. Your rights

Depending on where you are located, you may have rights to:

• access the personal data we hold about you;
• have inaccurate data corrected;
• request deletion of your data;
• restrict or object to certain processing;
• withdraw consent, where processing is based on consent; and
• receive certain data in a portable format.

Some of these rights are limited where we are legally required to retain records, in particular records held for anti-money-laundering and regulatory purposes. As explained in section 5, we cannot amend or delete information recorded on a public blockchain.

To exercise any right, please contact us using the details in section 14. We may need to verify your identity before responding.

11. Cookies and analytics

The Website uses cookies and similar technologies that are necessary for it to operate, together with limited analytics to understand aggregate usage. We do not use advertising cookies and we do not use cookies to build advertising profiles.

You can control cookies through your browser settings. Disabling necessary cookies may affect how the Website functions.

12. Children

The Website and the products described on it are intended for accredited and institutional investors. They are not directed at children, and we do not knowingly collect personal data from anyone under the age of 18.

13. Changes to this policy

We may update this policy from time to time. The date at the top of this page shows when it was last revised. Where a change is material, we will take reasonable steps to bring it to your attention.

14. Contact and complaints

For privacy questions, to exercise your rights, or to raise a complaint about how we handle personal data, contact:

Aarna AI Pte. Ltd.
[registered office address]
Email: privacy@aarna.ai

If you are not satisfied with our response, you may be entitled to complain to the data protection authority in your jurisdiction.