Acceptable Use Policy

This Acceptable Use Policy ("Policy") outlines the terms, conditions, and expectations governing the use of the CLIENT ASSET MANAGEMENT PLATFORM ("the Platform"), an online platform service owned by METACOMP PTE. LTD. ("MetaComp", "we", "us" or "our"), which is a Major Payment Institution bearing License No. PS20200499 issued by the Monetary Authority of Singapore ("MAS"). The Platform includes all related services, applications, interfaces, and systems made available to users ("Users" or "you"). Some web pages of the Platform are not operated by MetaComp, and the domain name does not belong to MetaComp as well. This is because MetaComp does not have the requisite license(s) to provide the products and services thereof, as such, they are operated by and offered by the parent company of MetaComp, ALPHA LADDER FINANCE PTE. LTD. ("ALFIN") which is a Capital Market Services license holder and a Recognised Market Operator.

By accessing, using, or interacting with the Platform, you agree to comply with all terms of this Policy. If you do not agree to abide by the terms of this Policy, you must immediately cease using the Platform and notify MetaComp at rcg-support@alphaladder.com immediately.

This Policy is part of our broader commitment to ensuring a secure, compliant, and trustworthy environment for our users, aligned with the requirements set forth by applicable laws, including but not limited to various applicable legislations such as the Payment Services Act 2019 ("PSA") for payment service providers like MetaComp, the Securities & Futures Act 2001 ("SFA") for capital market intermediaries like ALFIN, the Personal Data Protection Act 2012 ("PDPA"), the Financial Services and Markets Act 2022 ("FINSMA") and other relevant financial services regulations such as the various Notices, Guidelines and circulars issued to payment service providers and capital market intermediaries.

Unless otherwise defined herein, the defined terms in this Policy shall bear the same meaning as that stipulated in the Client Agreement that you have executed with MetaComp. As such, the terms under this Policy shall be adopted as terms and conditions of the Agreement and a breach of this Policy shall be a breach of the Agreement.

Compliance with Legal and Regulatory Framework. As a licensed financial institution under the oversight of the MAS, the Company is committed to complying with all applicable laws and regulations governing financial services, including but not limited to the FINSMA, PSA, SFA and/or the PDPA. These laws and regulations not only help to mitigate risks such as money-laundering or counter-terrorism financing but also ensures that the financial institutions put in controls to ensure a level of protection for its customers.

Users of the Platform must comply with all applicable regulatory and legal frameworks in their use of the Platform. The Company reserves the right to take appropriate action, including reporting suspicious activities to the relevant regulatory authorities or law enforcement agencies, in accordance with Anti-Money Laundering and Counter of Financing of Terrorism obligations.

Consumer Protection. Whilst the Platform itself has been designed to protect consumers, Users are encouraged to exercise caution and conduct proper due diligence (if need be) since payment services like cross border money transfers are known to be of higher risks of money laundering. As such Users should always understand the payor or payee, the purpose of the payment order and/or the payment transactions before actually following through with the relevant payment instruction on the Platform.

Account Integrity and Security. As a User of the Platform, you are entrusted with the responsibility of safeguarding your login credentials and other sensitive security information. You must take all reasonable precautions to protect your account and/or login credentials from unauthorized access. This includes, but is not limited to:

1. 1.using strong, unique passwords;
2. 2.enabling two-factor authentication (2FA) where available;
3. 3.ensure that your credentials are not shared with unauthorized individuals whether intentionally or unintentionally; and/or
4. 4.monitoring your account regularly for unauthorized or suspicious activities.

Suspicious Activities or Unauthorized Transactions. In the event that you suspect or detect any suspicious activity or unauthorized transactions in your account, you must notify us as soon as practicable and follow the proper reporting channel set out in the Agreement you signed with MetaComp. MetaComp reserves the right to terminate your account if MetaComp is of the view that there are reasonable grounds to suspect any fraudulent activity or security breach. This is to prevent further damage or compromise to your account during our investigation and/or review of the incident.

Use of the Platform. You are permitted to use the Platform solely for lawful purposes and in accordance with this Policy. This includes ensuring that all transactions, communications, and actions you undertake via the Platform comply with: (1) the terms and conditions set out in the Agreement; (2) any applicable Additional References and the contents thereof; (3) in accordance with any terms of use; and most importantly:

Payment Transaction. Any payment transactions performed through the Platform must be conducted in good faith and for legitimate purposes. Users are prohibited from using the Platform for:

1. 1.any purchase or sale of illegal goods or services;
2. 2.any attempt to circumvent legal controls, including the unauthorized transfer of assets or funds;
3. 3.the furtherance of any prohibited industries or activities. A list of such prohibited industries is set out in Table A: List of Prohibited Industries.

Money Laundering and Terrorist Financing. MetaComp maintains stringent measures such as the deployment of transaction monitoring tools and the maintenance of an end-to-end client narrative to mitigate the risk of money laundering and counter-terrorism financing. Apart from those controls, this Policy seeks to prohibit Users from using the Platform to engage in activities that facilitate or are connected to which include but are not limited to the following:

1. 1.money laundering or terrorism financing;
2. 2.the use of fictitious identities, fake accounts, or the creation of false financial records;
3. 3.concealing, transferring, or laundering proceeds from criminal activities;

Suspicious Transactions. Any suspicious transaction, regardless of value, will be flagged, and MetaComp shall have the right to freeze or terminate any User whose accounts are found to be conducting such activities. Additionally, MetaComp also has a duty to report such Users and the suspicious transactions to the Singapore Police Force.

Fraud and Misrepresentation. Users must not engage in fraudulent activities, including but not limited to any impersonation of other persons or entities, falsify or attempt to falsify documents, and/or attempt to gain unauthorized access to the Platform's systems.

Cybersecurity Violations. Users shall also avoid engaging in activities that may potentially disrupt or compromise the security or functionality of the Platform, including but not limited to: (1) the introduction of virus, malware, ransomware, or any malicious code into the Platform's infrastructure; (2) attempting to gain unauthorized access to any part of the Platform or its underlying infrastructure, including user data or payment processing systems; (3) the use of bots, scraping tools or other automated methods to extract information from the Platform without prior written authorization.

Intellectual Property Rights Infringement. Users shall not infringe or attempt to infringe any intellectual property rights of the Company, other Users and/or third parties. They should also refrain from reproducing, distributing, or otherwise exploit the Platform's context, marks, logos, designs and/or technology without authorization from MetaComp.

Monitoring and Audit. MetaComp regularly monitors the use of the Platform to ensure compliance with this Policy and the applicable regulations. This includes monitoring payment transactions, communication channels, and user activities. If you do not wish to be monitored as such, you shall cease using the Platform immediately and proceed with the Account Closure Request as set out in the Agreement. Should you continue to use this Platform, you shall be deemed to have acknowledged and consented to such monitoring.

MetaComp may implement automated systems, security checks, and auditing tools to detect unusual or suspicious activities. If such violations are identified, MetaComp may take the necessary steps to either suspend, restrict or terminate the User's accounts and/or commence a full investigation.

Reporting Violations. Users are encouraged to report any violations of this Policy, and you may lodge any violation report using the Contact Information in the last section of this Policy. All reports will be treated with confidentiality, and MetaComp will take appropriate steps to address any violations in accordance with its internal procedures and legal obligations.

Personal Data Protection. MetaComp is committed to protecting your personal data in accordance with the PDPA (kindly see the Privacy Policy). The continued use of the Platform shall be deemed to be your consent for the collection, processing, handling and/or storage of your personal data in the manner outlined in the Privacy Policy.

Data Security. MetaComp employs a range of technical and organizational security measures to safeguard your personal, financial, and transactional data from unauthorized access, alteration, or disclosure. However, due to the nature of online services, MetaComp cannot guarantee complete security, and Users are encouraged to take proactive steps to protect their own accounts.

Modifications and Updates. MetaComp reserves the right to amend, modify, or update this Policy at any time to reflect changes in the regulatory environment, business practices, or security measures. Any updates to this Policy will be published on the Platform, and the revised Policy will take effect immediately upon publication. Users are encouraged to review this Policy periodically.

No Liability for User-Generated Content. MetaComp does not accept liability for any loss, damage, or harm resulting from content uploaded, shared, or posted by Users, including financial losses, reputational damage, or security breaches.

Platform Use at Your Own Risk. Users agree to use the Platform at their own risk and acknowledge that MetaComp shall not be liable for any direct, indirect, incidental, consequential, or special damages resulting from the use or inability to use the Platform.