Consumer Protection and Regulatory Disclosures

Statutory disclosures and consumer-protection information for clients onboarded by Hex Technologies Pte. Ltd. under its Major Payment Institution licence with the Monetary Authority of Singapore.

Table of contents

1. Scope of Regulatory Licensing and Jurisdictional Boundaries
2. MAS Prescribed Statutory DPT Risk Warning
3. Targeted Institutional and Accredited Investor Eligibility Notice
4. Statutory Safeguarding of Customer Monies and Digital Assets
5. Pricing, Spreads, and Transaction Costs Transparency
6. Conflicts of Interest Management
7. Digital Payment Token Evaluation and Listing Policy
8. Protocol Network Events (Forks & Airdrops)
9. Business Continuity and Data Protection
10. Complaints Handling Framework
11. Personal Data Protection (PDPA) Policy
12. Website Usage, Third-Party Links, and Intellectual Property
13. General Disclaimers

1. Scope – Scope of Regulatory Licensing and Jurisdictional Boundaries

1. SCOPE

Hex Technologies Pte. Ltd. is licensed by the Monetary Authority of Singapore (“MAS”) as a Major Payment Institution under the Payment Services Act 2019. We are explicitly authorised to provide the following regulated payment services in Singapore:

• Cross-Border Money Transfer Services
• Digital Payment Token (DPT) Services

Clear Scope Separation

This disclosure portal relates exclusively to the products, services, and operational activities managed by the Singapore licensed entity, Hex Technologies Pte. Ltd.

Please be advised that this licence does not extend to, cover, or validate any value-added digital asset services featured on our global affiliate networks, including but not limited to decentralised or custodial DPT staking, token lending, asset wrapping, yield accounts, or digital payment token derivatives. These broader services are strictly not offered to clients onboarded via our Singapore corporation and remain wholly unregulated by MAS.

2. Statutory DPT Risk Warning – MAS Prescribed Statutory DPT Risk Warning

2. STATUTORY DPT RISK WARNING

The Monetary Authority of Singapore (MAS) requires us to provide this risk warning to you as a customer of a digital payment token (DPT) service provider. Before you (a) pay Hex Technologies Pte. Ltd. any money or DPT, or (b) pay any third party any money or DPT under an arrangement by Hex Technologies Pte. Ltd., you should be aware of the following:

14. Hex Technologies Pte. Ltd. is licensed by MAS to provide DPT services. Please note that this does not mean you will be able to recover all the money or DPTs you paid to Hex Technologies Pte. Ltd. or any other third party referred to above, if Hex Technologies Pte. Ltd.’s or the third party’s business fails. You should also be aware that a trust account or segregated account maintained by Hex Technologies Pte. Ltd. for your benefit may not fully protect your money or DPTs from loss if Hex Technologies Pte. Ltd.’s business fails.
15. You should be aware that MAS does not supervise or regulate Hex Technologies Pte. Ltd. for the provision of unregulated services. This includes any service of trading digital payment token derivatives such as futures.
16. You should not transact in the DPT if you are not familiar with this DPT. This includes how the DPT is created, and how the DPT you intend to transact is transferred or held by Hex Technologies Pte. Ltd.
17. You should be aware that the value of DPTs may fluctuate greatly. You should buy DPTs only if you are prepared to accept the risk of losing all of the money you put into such tokens.
18. You should be aware that Hex Technologies Pte. Ltd., as part of its licence to provide DPT services, may offer services related to DPTs which are promoted as having a stable value, commonly known as “stablecoins”.

3. Investor Eligibility – Targeted Institutional and Accredited Investor Eligibility Notice

3. INVESTOR ELIGIBILITY

The financial infrastructure and execution services provided on this website are exclusively directed at, marketed to, and structured for Accredited Investors and Institutional Investors as defined under Section 4A of the Securities and Futures Act 2001 (SFA) of Singapore.

Hex Technologies Pte. Ltd. does not service retail consumers in Singapore. By opting in to be treated as an Accredited Investor, you are afforded fewer statutory protections and remedies than retail investors. We are permitted to assume that Accredited Investors are better informed, better able to access resources to protect their own interests, and possess a certain level of understanding of digital payment tokens without us determining your precise level of understanding.

To qualify as an Accredited Investor under our onboarding framework, clients must meet strict statutory wealth thresholds, such as:

Individual

• Net personal assets exceed S$2,000,000 (or its equivalent in a foreign currency) in value, of which no more than S$1,000,000 (or its equivalent in a foreign currency) in value is contributed by the net estimated fair market value of my primary residence;
• Net financial assets exceed S$1,000,000 in value (or its equivalent in a foreign currency); or
• Income in the preceding twelve (12) months is not less than S$300,000 (or its equivalent in a foreign currency).

Corporation

• Net assets exceed S$10,000,000 (or its equivalent in a foreign currency) as determined by (a) its most recent audited balance-sheet or (b) its balance-sheet certified by the Corporation as giving a true and fair view of its state of affairs as of the date of the balance-sheet (which date is within the twelve (12) months preceding the date of submitting this form); or
• Entire share capital is owned by one or more persons, all of whom are accredited investors as defined in section 4A of the SFA.

4. Safeguarding – Statutory Safeguarding of Customer Monies and Digital Assets

4. SAFEGUARDING

Cross-Border Money Transfer (Fiat Monies)

All customer fiat monies received, accepted, or held by Hex Technologies Pte. Ltd. for the purpose of executing outbound or inbound cross-border money transfers are strictly safeguarded in accordance with Section 23 of the Payment Services Act. Customer funds are isolated from corporate operational revenue at all times and deposited into a dedicated client trust account maintained with our approved tier-1 safeguarding institution in Singapore, DBS Bank Ltd.

Digital Payment Token Services (Tokens)

Hex Technologies Pte. Ltd. establishes and maintains a custody Wallet for the deposit of Digital Assets on behalf of the client.

• Absolute Segregation: The Digital Assets deposited by the Client into the Wallet will not be commingled with the Digital Assets from the Custodian’s other customers.
• Statutory Trust: We declare that we hold all relevant right, title, and interest in and to such Digital Assets on bare trust for the benefit of the Client absolutely.
• Bankruptcy Remoteness: The Wallet is designated as a trust account, distinguishable and maintained separately from any proprietary assets. The Digital Assets in the Wallet are not general assets of Hex Technologies Pte. Ltd., are not available to satisfy claims of any creditors, and cannot be used for the payment of the debts of the Custodian.

5. Pricing transparency – Pricing, Spreads, and Transaction Costs Transparency

5. PRICING TRANSPARENCY

Hex Technologies Pte. Ltd. enforces complete pricing transparency across all transaction legs:

• Exchange Rates & Remittance Fees: Exchange rates applied to cross-border money transfers are determined based on prevailing wholesale interbank spot rates plus a pre-disclosed conversion spread.
• Third-Party & Intermediary Charges: Institutional cross-border transfers may be subject to standard Deductions at Source, correspondent banking fees, or destination routing fees that occur outside our administrative perimeter. These are borne by the transacting party unless otherwise contracted.
• OTC Spreads: Executable spot quotes generated for DPT trading represent institutional liquidity depths and incorporate an integrated commercial spread.
• Blockchain Gas Fees: Clients bear full responsibility for the network transaction fees (“gas”) mandated by native public blockchains to clear token withdrawals.

6. Conflicts of interest – Conflicts of Interest Management

6. CONFLICTS OF INTEREST

Hex Technologies Pte. Ltd. maintains rigorous policies and procedures designed to identify, monitor, and mitigate any potential, perceived, or actual conflicts of interest that may arise in the course of providing regulated payment services. We operate our institutional liquidity desk with strict functional segregation. Where Hex Technologies Pte. Ltd. acts as a principal counterparty in an Over-the-Counter (OTC) transaction, this will be transparently disclosed prior to execution, ensuring alignment with MAS market conduct expectations and best execution principles.

7. DPT listing policy – Digital Payment Token Evaluation and Listing Policy

7. DPT LISTING POLICY

We manage a strict internal due diligence process governing which digital payment tokens are supported on our infrastructure:

• Listing Assessment: Prior to onboarding any token, our Risk Committee evaluates its regulatory classification under Singapore law, protocol stability, cryptographic vulnerability history, smart contract audit records, and liquidity concentration vectors.
• Suspension & Delisting: We reserve the unconditional right to suspend or delist support for any asset in the event of severe blockchain consensus failure, regulatory prohibition in Singapore, or absolute market illiquidity. Clients will be granted reasonable notification periods to withdraw impacted tokens, subject to blockchain operational availability.

8. Network events – Protocol Network Events (Forks & Airdrops)

8. NETWORK EVENTS

The blockchain protocols underlying supported digital assets are subject to sudden modifications. Hex Technologies Pte. Ltd. evaluates the support of new tokens generated by a Hard Fork or Applicable Airdrop at its sole discretion.

We will evaluate conditions including, but not limited to:

• The technical stability and safety of the network, including replay and wipeout protection.
• Global measurable value exceeding USD 100 million and sustained daily liquidity of at least USD 25 million on trustworthy exchanges.
• Receipt of at least ninety (90) days prior notice regarding the introduction of the event to ensure sufficient time to manage the distribution.

9. Business continuity – Business Continuity and Data Protection

9. BUSINESS CONTINUITY

Hex Technologies Pte. Ltd. maintains rigorous operational resilience and data protection frameworks:

• Business Continuity: We maintain comprehensive Business Continuity Plans (BCPs) to ensure the continuity of our critical business functions. For the provision of custody services for securities and digital payment tokens, our Service Recovery Time Objective (SRTO) is four (4) hours.
• Data Security & PDPA: We implement physical, electronic, and procedural safeguards to protect personal data, including transmitting all personal information via Secure Socket Layer (SSL) technology and enforcing multi-factor authentications on systems storing personal data.
• Data Retention: Personal data and records of transactions will be retained for a period of at least five (5) years from the date the business relationship ends. For privacy inquiries, our Data Protection Officer can be reached at dpo.sg@hextrust.com.

10. Complaints handling – Complaints Handling Framework

10. COMPLAINTS HANDLING

Hex Technologies Pte. Ltd. is committed to delivering the highest level of service. A complaint is defined as an expression of dissatisfaction about Hex Trust’s action or lack of action relating to a product or standard of service. Formal complaints should be directed to our independent compliance desk at compliance.sg@hextrust.com.

Our Resolution Protocol & Timelines

Written Acknowledgement: All complaints will be acknowledged in writing. The timeframe for issuing an acknowledgement depends on the method of submission:

• In Person: Acknowledged on the spot.
• Online Complaint: Acknowledged within one (1) day from receipt.
• Written Complaint: Acknowledged within three (3) days from receipt.

The formal acknowledgement will state the name, job title, and contact details of the independent person handling the complaint, alongside expected timelines for investigation.

Impartial Investigation & Resolution: We target the prompt resolution of issues according to operational complexity:

• Regular complaints: Resolved within 24 hours to 3 days.
• Medium / Complex issues: Resolved within up to 5 days.
• Very complex issues: Resolved within 7 to 10 days.

Interim Status Triggers: If a complaint cannot be resolved within the specified timeframe due to complexity, an interim reply will be issued to the complainant by day 10, advising them of the status and expected resolution date.

Record Keeping: Detailed records of complaints, including the assessment result and correspondence, are retained for a period of at least 5 years from the date of receipt.

11. PDPA – Personal Data Protection (PDPA) Policy

11. PDPA

Hex Technologies Pte. Ltd. strictly complies with the Personal Data Protection Act 2012 (PDPA) of Singapore in the collection, use, disclosure, and safeguarding of your personal data.

Collection of Personal Data

We collect personal data strictly for reasonable business purposes and regulatory compliance. The types of personal data we collect and hold about our institutional clients, their authorised users, and beneficial owners include:

• Identifying & Contact Information: Names, nationality, date of birth, passport/identity documents, business registration details, residential/business addresses, email addresses, and telephone numbers.
• Financial & Digital Asset Data: Financial information, blockchain identifiers (such as public keys and wallet addresses), and records of products or services utilised.

Use and Disclosure of Personal Data

We use and disclose personal data only for the purposes for which it was provided, or as legally required. These purposes include:

• Verifying client identities and performing Know-Your-Customer (KYC) obligations.
• Processing payment, credit, or digital asset transactions, and executing requested services.
• Responding to queries, requests, and managing the ongoing client relationship.
• Complying with applicable laws, regulations, and assisting in law enforcement investigations conducted by relevant governmental or regulatory authorities.

Third-Party Disclosures: Hex Technologies Pte. Ltd. does not distribute client information to non-affiliated third parties except as authorised by the client, or to approved service providers under a strict duty of confidentiality. Where personal data is transferred outside of Singapore, we ensure that the recipient jurisdiction affords a standard of protection comparable to that provided under the PDPA.

Data Protection and Security Safeguards

We implement robust physical, electronic, and procedural safeguards to protect personal data against unauthorised access, use, or disclosure. Our security measures include the use of Secure Socket Layer (SSL) technology for data transmission, strict data-at-rest encryption protocols, and multi-factor authentication (MFA) for systems housing personal information.

Data Retention

Personal data is retained only for as long as necessary to fulfil the business or legal purposes for which it was collected. In accordance with our compliance policies, client personal data and transaction records are retained for a minimum period of five (5) years from the termination of the business relationship, whichever occurs last.

Access, Correction, and Data Protection Officer (DPO)

Clients have the statutory right to request access to their personal data, inquire about how it has been used or disclosed over the past year, and request the correction of any errors or omissions. We will endeavour to respond to all valid access and correction requests within 30 days.

To exercise these rights, withdraw consent for data usage, or submit a privacy-related inquiry, please contact our designated Data Protection Officer at dpo.sg@hextrust.com.

12. Website terms – Website Usage, Third-Party Links, and Intellectual Property

12. WEBSITE TERMS

“As Is” and “As Available” Basis

The information, materials, and services provided on this website are provided on an “as is” and “as available” basis. While Hex Technologies Pte. Ltd. makes every effort to ensure the accuracy and reliability of the information presented, we do not warrant that the website will operate uninterrupted, be error-free, or that defects will be corrected. We expressly disclaim all implied warranties, including but not limited to warranties of merchantability, fitness for a particular purpose, and non-infringement.

Limitation of Website Liability

To the maximum extent permitted by applicable Singapore law, Hex Technologies Pte. Ltd., its affiliates, directors, and employees shall not be liable for any direct, indirect, incidental, special, punitive, or consequential damages, including but not limited to loss of business, loss of profits, loss of revenue, or loss of opportunity, arising out of or in connection with your access to, use of, or inability to use this website. This includes damages resulting from viruses, malware, or other malicious software that may infect your computer equipment or other property on account of your access to the site.

Third-Party Services and External Links

This website may contain integrations or hyperlinks to websites, applications, and services operated by external third-party providers. These links are provided solely for your convenience and information.

• Hex Technologies Pte. Ltd. does not endorse, monitor, or exercise control over the content, privacy policies, or operational standards of these third-party services.
• We make no warranties, express or implied, regarding the accuracy, completeness, or reliability of third-party content.
• You acknowledge and agree that your access to and use of any third-party service is entirely at your own risk, and Hex Technologies Pte. Ltd. assumes no liability for any loss or damage resulting from your engagement with such external platforms.

Intellectual Property and Trademarks

All content displayed on this website, including but not limited to text, graphics, logos, icons, images, audio clips, digital downloads, and software architecture, is the exclusive property of the Hex Trust Group or its content suppliers and is protected by Singapore and international copyright and trademark laws.

• Hex Technologies Pte. Ltd. grants you a limited, non-exclusive, and non-transferable licence to access and use the website for its intended institutional purposes.
• You may not systematically extract, re-utilise, reproduce, duplicate, or copy any part of this website without our express prior written consent.
• Nothing contained on this website should be construed as granting any right or licence to use any trademark displayed on the site without the prior written permission of Hex Technologies Pte. Ltd. or the respective third-party owner.

13. General disclaimers – General Disclaimers

13. GENERAL DISCLAIMERS

No Investment, Financial, or Fiduciary Advice

Hex Technologies Pte. Ltd. operates strictly on an execution and custodial basis. We do not act as a fiduciary, financial planner, investment adviser, or portfolio manager for our clients. No communication, whether written, oral, or published on this website, should be construed as investment advice, a recommendation to enter into any transaction, or an assurance regarding the expected results of any digital asset activity. Clients must conduct their own due diligence, seek independent professional advice, and evaluate their own financial risk tolerance before engaging our services.

High Volatility and Market Risk

We cannot guarantee the value of any Digital Payment Token (DPT) and provide no such assurance. The value of virtual assets is highly volatile, largely speculative, and often lacks traditional intrinsic value foundations. By trading or holding DPTs, you acknowledge and agree that you accept a significant risk of loss. The value of virtual assets can fluctuate rapidly, experience extreme illiquidity, and may even decline to zero.

Exclusions from Deposit Insurance

Digital Payment Tokens and fiat monies deposited with Hex Technologies Pte. Ltd. for the purposes of custody or cross-border money transfers do not constitute standard bank deposits. Consequently, your assets and funds are not insured or protected by the Singapore Deposit Insurance Corporation (SDIC).

Anti-Fraud and Security Warning

The decentralised nature of virtual assets exposes them to heightened risks of fraud, cyber-attacks, and phishing. Please note that Hex Technologies Pte. Ltd. and its authorised personnel will never request users to disclose their account passwords, two-factor authentication (2FA) codes, online banking credentials, or debit/credit card CVV numbers. Furthermore, we will never instruct clients to make payments in person or via cash remittance services (e.g., Western Union). Clients are solely responsible for verifying the authenticity of communication channels before transferring funds or tokens.

Underlying Blockchain and Technology Risks

The technological infrastructure supporting Digital Payment Tokens is subject to inherent vulnerabilities. Hex Technologies Pte. Ltd. is not responsible for losses caused by external network events beyond our direct operational control. These include, but are not limited to:

• Protocol Vulnerabilities: Intentional or unintentional bugs, logic errors, or defects in the underlying open-source smart contracts or blockchain code.
• Network Attacks: Malicious consensus-based attacks, 51% majority mining power attacks, distributed denial of service (DDoS) attacks, or Sybil attacks on public blockchains.
• Irreversible Action: Cryptocurrency transactions are irreversible. Any transfer executed to a wrong public address provided by the client cannot be reversed, and the associated assets will be permanently lost.

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