HELIOS
LEGAL — DOCUMENT 2 of 3

Privacy Policy

Version 0.1 · Effective 2026-05-03 · Operator: KTR Capital, LP (Texas)

Version 0.1 — Template pending attorney review. Working draft. Final language must be reviewed by counsel, especially any GDPR / CCPA additions if you accept users from those jurisdictions.

This Privacy Policy describes how KTR Capital, LP ("Helios", "we", "us") collects, uses, and shares personal information in connection with the Helios Markets website, applications, and APIs (the "Service"). By using the Service you agree to this Policy.

1. Information We Collect

Information you provide

Information collected automatically

2. How We Use Information

3. Legal Bases (where applicable)

Where the GDPR or similar laws apply, we process personal data on the bases of (i) performing our contract with you, (ii) our legitimate interests in operating and improving the Service, (iii) your consent (e.g., for cookies in some jurisdictions), and (iv) compliance with legal obligations.

4. How We Share Information

We do not sell your personal information. We share information only as necessary to operate the Service:

5. Data Retention

We retain account and usage information for as long as your account is active and for a reasonable period thereafter to comply with legal, tax, accounting, and dispute resolution obligations. Billing records may be retained for up to seven (7) years to satisfy U.S. tax requirements. You may request deletion of your account and personal data at any time by contacting us, subject to records we are required to keep.

6. Security

We use industry-standard technical and organizational measures to protect personal information, including encrypted transport (TLS), hashed passwords, restricted internal access, and audit logging. No system is perfectly secure, and we cannot guarantee absolute security.

7. Your Rights

Depending on your jurisdiction, you may have rights to (i) access the personal information we hold about you, (ii) correct inaccurate information, (iii) request deletion, (iv) restrict or object to certain processing, and (v) request portability of your data. To exercise these rights, email privacy@helios.markets. We will respond within the timeframes required by applicable law.

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information is collected and the right to opt out of any "sale" (we do not sell personal information).

8. International Transfers

Helios is operated from the United States. If you access the Service from outside the United States, your information may be transferred to and processed in the United States, where data protection laws may differ from those in your country.

9. Children's Privacy

The Service is not directed to children under 18. We do not knowingly collect personal information from anyone under 18.

10. Changes to this Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by updating the effective date above and, where appropriate, by email or in-product notice.

11. Contact

Privacy questions: privacy@helios.markets

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