Privacy Policy(Treatment of Personal Information)
Alphadyne Asset Management Holdings Limited (“Alphadyne Japan”) shall manage handling,etc. of personal information, individual number, and specific personal information (individual
number and specific personal information collectively referred to as the “Specific Personal
Information, Etc.”) in accordance with the Act on the Protection of Personal Information (the“APPI”), Act on the Use of Numbers to Identify a Specific Individual in Administrative
Procedures (the “Individual Numbers Act”) and other laws and regulations, the rules of theAccredited Personal Information Protection Organization that it is a member of, and internal
rules, etc., and shall take adequate measures for safety control of such information.
1. Definitions
Except as defined in the following paragraphs, terms defined in the APPI or the Individual
Numbers Act shall have the same meanings in this Privacy Policy.
(1) “Clients” shall refer to individual clients and individuals who belong to a client
corporation, individuals who are prospective clients and individuals who belong toa corporation which is a prospective client, and individuals who belong totransaction counterparties and issuers, etc.
(2) “Employees” refers to employees of Alphadyne Japan.
(3) “Data Subjects” refers to Clients and Employees.
(4) "Personal Information" shall refer to information pertaining to living individuals
that enables identification of a specific person through name, date of birth and otherstatement included in such information (including those that can be easily
reconciled with other information which results in identification of such individual).
(5) “Personal Information Database” refers to an assembly of information including
Personal Information systematically arranged in such a way that specific Personal
Information can be retrieved by a computer; or even without the use of a computer,an assembly of information including Personal Information systematically arranged
in such a way that specific Personal Information can be easily retrieved such as byapplying certain rules including with alphabetically indexed and ordered client
cards, that are maintained to enable generally easy retrieving with table of contents,
index, codes, etc.
(6) “Personal Data” refers to Personal Information constituting a Personal Information
Database.
(7) “Individual Number” refers to the number obtained by converting the resident

record code and designated for identification of the person for whom such resident
record code is stated on the resident record, and which is specified in the Individual
Numbers Act, Article 7, Paragraph 1 and 2.
(8) “Specific Personal Information” refers to Personal Information that includes
Individual Numbers (including numbers, signs and other symbols corresponding toand used in lieu of the Individual Number other than the resident record code).
(9) “Retained Personal Data” refers to Personal Data that Alphadyne Japan has theauthority to disclose, correct, add or delete the contents of, cease the utilization of,erase, and cease the third-party provision of, and which shall not harm the public orother interests if their presence or absence is made known.
(10) “Alphadyne” refers to Alphadyne Asset Management LP, Alphadyne AssetManagement (UK) LLP, Alphadyne Asset Management (Hong Kong) Limited,
Alphadyne (Singapore) Pte. Ltd and Alphadyne Japan.
2. Method of Acquisition and Type of Personal Information(1) Alphadyne Japan shall acquire minimum Personal Information (excluding Specific
Personal Information, Etc. The same shall apply hereinafter in this Section 2.)
necessary for the business by proper means.
(2) Types of Personal Information of Clients to be acquired includes the following
items:(a) Name(b) Address, telephone number, facsimile number, e-mail address(c) Name, address, telephone number, facsimile number, e-mail address of theemployer(d) Title held at the employer(3) Types of Personal Information regarding Employees to be acquired are set forth in
the Japan Employee Data Protection Policy.
3. Purpose of Use of Personal Information(1) Alphadyne Japan shall use the Personal Information (excluding Specific Personal
Information, Etc. The same shall apply hereinafter in this Section 3) for business,
etc. conducted by Alphadyne Japan.
(2) Alphadyne Japan shall not use Personal Information in a manner that is likely to
encourage or induce illegal or unjust acts.
(3) Alphadyne Japan shall specify the purpose of use each time written Personal
Information is to be acquired directly from a Data Subject in advance.
(4) Alphadyne Japan shall use Personal Information of Clients for the following
purposes only:

(a) Solicitation/proposal concerning the business, etc. conducted by Alphadyne
Japan or notice of services(b) To determine appropriateness of provision of investment products andservices in light of principle of suitability, etc.
(c) Confirmation of the Client or his/her representative's identity(d) Provision of investment advisory service(e) Reporting of investment results and asset balance, etc. to the Client(f) Administration of transaction with the Client(g) To study and develop investment products, financial products or services byconducting market research, data analysis, and surveys, etc.
(h) Otherwise for appropriate and smooth performance of transactions with
Clients(5) Alphadyne Japan shall use Personal Information of Employees for the purposes set
forth in the Japan Employee Data Protection Policy. To the extent the terms of thisPrivacy Policy conflict with the Japan Employee Data Protection Policy, the termsof the Japan Employee Data Protection Policy shall govern Personal Information of
Employees.
(6) Alphadyne Japan shall use Personal Information to the extent necessary for
performance of its business within the scope of purpose of use and shall not use thesame for other purposes.
(7) The purpose of use shall be made publicly available by measures including postingof this Privacy Policy on the home page of Alphadyne Japan.
4. Provision of Personal Information to Third Parties(1) Alphadyne Japan will not provide Personal Information (excluding Specific
Personal Information, Etc. The same shall apply hereinafter in this Section 4) of theData Subject to a third party without the consent of the Data Subject; provided,
however, that necessary scope of Personal Information of a Data Subject may beprovided to a third party as an exception in the following cases:(a) In case it is based on the laws(b) In case the business is outsourced in accordance with the purpose of use(c) In case of re-entrustment of investment(d) In case Personal Information is deposited with a third party to outsource thebusiness of handling Personal Data
(In the case of (b), (c), or (d) above, necessary measures under the law will
be taken, including investigation of such subcontractor/third party andexecution of necessary contracts.)(2) In the case that Alphadyne Japan provides Personal Information to a third party

located in a foreign country with the consent of the Data Subject, and when
Alphadyne Japan is unable to identify the foreign country in which the third party
to which the Personal Information is provided is located at the time of obtaining theData Subject's consent, (a) Alphadyne Japan shall, upon the Data Subject's request,
provide the Data Subject with information regarding the name of the foreign country,
etc. in accordance with the APPI if it becomes possible to identify such foreigncountry after such consent, and (b) Alphadyne Japan shall, upon the Data Subject's
request, provide the Data Subject with information on measures taken by the third
party to protect Personal Information if it becomes possible to provide information
on such measures after such consent. In addition, when Alphadyne Japan provides
Personal Information to a foreign country without the consent of the Data Subject,
Alphadyne Japan shall, in accordance with the APPI, provide the Data Subject withinformation on measures necessary to ensure the third party’s continuous
implementation of measures equivalent to those required to be taken by businesses
handling Personal Information, upon the Data Subject's request.
5. Joint Use of Personal Information.
Alphadyne Japan may jointly use all or part of Personal Information of Data Subjects
acquired by Alphadyne Japan as stated below.
(1) Items of the jointly used Personal Information
Personal Information described in Section 2, Paragraph 3(2) Scope of entity jointly using such Personal Information
Alphadyne Asset Management LP (U.S.A.)
Alphadyne Asset Management (UK) LLP (UK)
Alphadyne Asset Management (Hong Kong) Limited (China)
Alphadyne (Singapore) Pte. Ltd. (Singapore)(3) Purpose of use for the entity jointly using such Personal Information
Purpose described in Section 3, Paragraph 5(4) Entity responsible for management of such Personal Information jointly used
Alphadyne Japan
6. Purpose of Use of Specific Personal Information, Etc.
(1) Alphadyne Japan shall acquire and use Specific Personal Information, Etc. within
the scope prescribed in the Individual Numbers Act.
(2) Alphadyne Japan shall not use Specific Personal Information, Etc. in a manner thatis likely to encourage or induce illegal or unjust acts.
(3) Alphadyne Japan shall specify the purpose of use each time written Specific
Personal Information, Etc. is to be acquired directly from a Data Subject in advance.

(4) Alphadyne Japan shall use Specific Personal Information, Etc. to the extent
necessary for performance of business within the scope of purpose of use and shallnot use the same for other purposes.
7. Provision of Specific Personal Information, Etc. to Third Parties
Alphadyne Japan shall not provide Specific Personal Information, Etc. of the Data Subject
to a third party other than in cases permitted under the Individual Numbers Act, regardlessof the Data Subject’s consent or approval.
8. Method for Management of Personal Data and Specific Personal Information, Etc.
(1) Appropriate measures will be taken to ensure that the Data Subject’s Personal Dataand Specific Personal Information, Etc. are accurate and latest information.
(2) Appropriate information security measures will be taken to prevent loss, destruction,
alteration, and leaks, etc. of the Data Subject’s Personal Data and Specific Personal
Information, Etc. For more information on the safety control measures implemented
by Alphadyne Japan, please contact the contact office set forth in Section 11.
9. Request for Notice of Purpose of Use, Disclosure, Revision/Addition/Deletion, Suspensionof Use, Erasure, and Suspension of Provision to Third Parties of Retained Personal Data
and Disclosure of Third Party Provision Records from the Data Subject (collectively
referred to as “Disclosure”)(1) Notice of Purpose of Use, Disclosure, and Revision/Addition/Deletion of Retained
Personal Data and Disclosure of Third Party Provision Records(a) In case the Data Subject requests notice of purpose of use or disclosure of
information concerning the Data Subject or disclosure of third party
provision records, response to such requests will be given unless there are
specific reasons not to, subject to confirmation that the requester is the Data
Subject or the Data Subject’s representative.
(b) In case the information concerning the Data Subject is inaccurate, it will be
replaced with accurate information.
(2) Suspension of Use, Erasure, and Suspension of Provision to Third Parties of
Retained Personal Data
In case the Data Subject requests suspension of use, erasure, or suspension ofprovision to third parties of information concerning such Data Subject, measures tosuspend use, erase, suspend provision to third parties, etc. will be taken unless thereis specific reason not to.
10. Procedure for Request on Retained Personal Data Disclosure from Data Subject

(1) Items Subject to Request for Disclosure
Items of “Retained Personal Data” subject to Disclosure include the items set forthin Section 2, Paragraph 2 and Section 2, Paragraph 3:(2) Application for Disclosure
Please make application for Disclosure by post addressed to the contact stated in
Section 11, Paragraph 1, using the designated application form with attachment of
personal identification documents, etc. Please state “Disclosure Request Documents”
on the envelope.
(3) Documents to be Submitted for Requesting Disclosure(a) Request by the Data Subject: Please send designated application form andpersonal identification documents.
(b) Request by the Data Subject’s representative: In addition to the designatedapplication form and personal identification documents, please submit thedesignated power of attorney, etc., and personal identification documents of
the representative as specified below.
(i) Request by Legal Representative
a. Document stating the legal representative rights (any format)
b. Document for confirming the legal representative right(certificate of registered information of the adult guardiansystem; provided, however, that a copy of transcript/extractof family register or resident certificate showing both theData Subject and the legal representative and theirrelationship may suffice if the legal representative is a personwith parental authority)c. Personal identification document for the legal representative(ii) In case of representative through power of attorneya. Designated power of attorney (please affix the seal that isaffixed on the Certificate of Seal Impression of the Data
Subject)
b. Certificate of Seal Impression of the Data Subject
c. Personal identification document of the representative(c) Please contact the address stated in Section 11, Paragraph 1 to request for
application form and power of attorney, etc.
(4) Method for Requesting Disclosure
By postal mail.
(5) Method for Confirmation of the Person or Representative of the Requester ofDisclosure
Please send the original or copy of formal documents such as driver’s license,various insurance certificates, passport, certificate of alien registration.
(6) Fee for Disclosure
Disclosure shall be made free of charge; provided, however, that any expense
incurred by the Data Subject for sending the application form and personal
identification documents, etc. to Alphadyne Japan shall be borne by the Data
Subject.
(7) Items Required for Identification of Retained Personal Data or Third Party
Provision Records
Alphadyne Japan may request the Data Subject to present items required for
identification of Retained Personal Data or third party provision records withrespect to the request for Disclosure. Items required for identification of Retained
Personal Data or third party provision records are the name, address, and telephone
number of the Data Subject, and the name, address, and telephone number of theemployer.
(8) Method of Reply
In principle, reply will be provided in writing by postal mail addressed to theaddress stated on the application form; provided, however, that the disclosure shallbe made by means that the Data Subject requests (or by paper-based document, incases where disclosing the information by such means would require a costly
expenditure or otherwise be difficult). Please note that the reply may take timedepending on the information requested for Disclosure.
(9) Purpose of Use of Retained Personal Data Acquired in Conjunction with Request
for Disclosure
Retained Personal Data acquired by Alphadyne Japan in conjunction with therequest for Disclosure shall be used only within the scope necessary for request forDisclosure.
*Reason for Refusal to Disclose Retained Personal Data and Third Party Provision Records
In case any of the following reasons apply, disclosure will be refused. In case a decision ismade to refuse disclosure, such fact and reason will be notified.
・ In case personal identification cannot be made, such as mismatching of addressstated on the application, personal identification documents, and Alphadyne Japan’s
Retained Personal Data.
・ In case the right of representation cannot be confirmed for application by the
representative
・ In case there is a defect in designated application form
・ In case the request for disclosure is not for “Retained Personal Data”
・ In case the disclosure is likely to harm the life, body, property, or other rights orinterests of the Data Subject or a third party
・ In case the disclosure is likely to seriously impede the proper execution of thebusiness of Alphadyne Japan・ In case the disclosure violates other laws
11.

Contact for Inquiries and Complaints from Data Subject(1) Contact for Inquiries and Complaints Concerning Personal Information andSpecific Personal Information, Etc.
Inquiries and complaints, etc. concerning handling of Personal Information andSpecific Personal Information, Etc. from Data Subjects shall be handledappropriately by the following contacts, etc. Please contact via telephone or inwriting.
Alphadyne Asset Management Holdings Limited
Otemachi Park Building, 1-1-1 Otemachi, Chiyoda-ku, Tokyo, 100-0004
Representative in Japan Tatsuya Takeda
Compliance Officer (03) 4588-3100(Business Hours: 9:00 to 17:00 excluding the weekend, public holidays and nonbusiness days around year-end and New Year)(2) Name of the Accredited Personal Information Protection Organization that it is a
Member of, and Customer Complaints/Consultation Contact Information(a) Japan Investment Advisers Association (03)3663-0505(b) Type II Financial Instruments Firms Association (03)6910-3980

12.
Revisions
The contents of this Privacy Policy shall be reviewed as necessary for revision of laws andother reasons, and Alphadyne Japan will endeavor to make ongoing improvements.
Supplementary Provisions
These Rules shall become effective on February 1, 2024.