Privacy Policy
Truth Meter ("we", "our", or "us") is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information in accordance with applicable data protection laws in Hong Kong, Singapore, and the United Arab Emirates.
Jurisdictions Covered
- Hong Kong: Personal Data (Privacy) Ordinance (Cap. 486)
- Singapore: Personal Data Protection Act 2012 (PDPA)
- UAE: Federal Decree-Law No. 45 of 2021 on Personal Data Protection (PDPL)
1. Data We Collect
We collect only the minimum data necessary for our services:
- Identity Data: Name, company name, job title
- Contact Data: Email address, phone number, business address
- Technical Data: IP address, browser type, device information
- Usage Data: Pages visited, features used, time spent
- Transaction Data: Verification hashes, oracle confirmation records (processed via ICP blockchain, not stored as personal data)
2. How We Use Your Data
We use collected data solely for:
- Providing and improving our institutional verification infrastructure
- Oracle verification and trust scoring
- Regulatory compliance (SFC, MAS, VARA requirements)
- Responding to your inquiries and support requests
- Sending service-related communications
We do not sell, trade, or rent your personal data to third parties.
3. Legal Basis for Processing
Under applicable data protection laws:
- Hong Kong (PDPO): Compliance with Legal Obligations (s. 58(2)(b)) and Contract Performance (s. 58(2)(a))
- Singapore (PDPA): Business Improvement Exception (s. 20(a)) and Legitimate Interests (s. 20(d))
- UAE (PDPL): Contract Performance (Art. 4) and Legal Obligation (Art. 4)
4. Data Sharing
We share your data only with:
- Regulatory Bodies: HK SFC, MAS, Dubai VARA — as required by law
- Service Providers: Cloud infrastructure (AWS/Google Cloud), CRM systems — under strict data processing agreements
- Legal Requirements: When required by court order or regulatory investigation
All third-party processors are contractually bound to maintain equivalent data protection standards.
5. Data Retention
We retain your data only as long as necessary:
| Data Type | Retention Period |
|---|---|
| Account Data | Duration of relationship + 7 years for regulatory compliance |
| Verification Records | 7 years (immutable audit trail on ICP blockchain) |
| Marketing Data | Until you withdraw consent |
| Technical Data | 2 years for security purposes |
6. Your Rights
You have the following rights under applicable laws:
- Access: Request a copy of your personal data
- Correction: Request correction of inaccurate data
- Deletion: Request deletion (subject to regulatory retention requirements)
- Portability: Receive your data in structured, machine-readable format
- Withdrawal: Withdraw consent at any time (where processing is consent-based)
- Object: Object to processing based on legitimate interests
To exercise any of these rights, contact us at eddy@highperformanceadvisory.com.
7. Security Measures
We implement industry-standard security measures:
- 256-bit AES encryption for data at rest
- TLS 1.3 encryption for data in transit
- Multi-factor authentication for all administrative access
- Regular security audits and penetration testing
- SOC 2 Type II compliance — certification in progress (for core infrastructure)
8. International Data Transfers
Your data may be processed in jurisdictions outside your residence. When we transfer data internationally, we ensure:
- Adequacy decisions or equivalent protections are in place
- Standard Contractual Clauses (SCCs) are executed with all processors
- Data localization for regulatory-required records (HK, Singapore, UAE)
9. Cookies & Tracking
We use essential cookies only — see our Cookie Policy for full details.
10. Children's Privacy
Our services are designed for institutional investors and financial professionals. We do not knowingly collect data from individuals under 18 years of age.
11. Changes to This Policy
We may update this Privacy Policy periodically. We will notify you of material changes via email and post the updated policy with a revised "Last Updated" date.
12. Contact Us
If you have questions about this Privacy Policy or wish to exercise your rights:
- Email: eddy@highperformanceadvisory.com
- Mail: Truth Meter, c/o High Performance Advisory, Hong Kong
We will respond to all inquiries within 30 days as required by applicable data protection laws.