DRAFT. Not approved by counsel and not final. Do not rely on it.

Pewter Privacy Policy

Effective date: [CONFIRM: date of publication]

This policy explains what personal data we collect when you use Pewter, why we collect it, who we share it with, how long we keep it, and what rights you have. We have tried to keep it plain and short.

To manage or delete your data, see Your privacy choices at https://omegacompute.com/privacy-choices.

1. Who we are

The company responsible for your personal data (the "controller") is HEIR PTE. LTD. (UEN 202449113D), a company registered in Singapore. We do business as Omega Compute. In this policy, "we" and "us" mean HEIR PTE. LTD.

"Pewter" means the Pewter iPhone app, the Pewter servers and programming interfaces it connects to, and the website at omegacompute.com. This policy covers all three.

2. Pewter is a sandbox for now

Pewter deals use test money. Balances, deal amounts, fees and payouts for Pewter deals are sandbox figures. No real funds move through a Pewter deal. Many figures in the sandbox, such as delivery and uptime, are simulated, and the other side of a sandbox deal may be a scripted counterparty run by us.

Referrals, levels, badges and the Daily Forge carry no money. Referral rewards are points only, and points, levels, badges, packs and Forge items have no cash value. See the Referral Program Rules, the Levels and badges rules, the Daily Forge rules and the Wallet disclosure.

The Pewter wallet does not change this. The wallet is non-custodial: it lives on your phone, and we never hold your key or your funds. By default it uses a test network. The app can also show a view-only Mainnet view of your real USDC balance, but no Pewter deal settles on Mainnet. See section 9.

In-app purchases go through Apple. If you buy a subscription or boosts in the app, Apple takes the payment. We do not receive your card or bank details. [CONFIRM: keep this paragraph only if the in-app purchase build ships; counsel's 27 October 2026 email says in-app purchase of Pro, Foundry and the boosts is in the United States launch.]

If we ever offer live services that involve real money or real compute, we will update this policy before we start collecting any new kinds of data. That would include identity checks, payment details and sanctions screening.

3. The data we collect

Data you give us or that Apple gives us when you sign in

Sign in with Apple is the only way to sign in. We receive:

Data created when you use Pewter

Data from your use of the website

When you visit omegacompute.com, our servers and our network provider receive your IP address, browser details, and the page you asked for. The website does not set cookies of its own and does not use analytics or advertising tools. See section 12.

What we do not collect

We do not collect payment card data, bank account details, precise location, contacts, photos or videos, audio, health data, sensitive information, your browsing or search history, or advertising identifiers. We never receive your wallet's private key or recovery phrase. Face ID is handled by iOS on your device. We never receive your face data or fingerprint. We do not use third-party analytics or advertising tools in the app. We do not buy data from or sell data to data brokers. We do not track you across other companies' apps or websites.

4. Why we use your data and our legal bases

What we doWhyLegal basis (GDPR Article 6) and PDPA concept
Sign you in, keep you signed in, create and run your sandbox account, show your balance, listings, requests, deals and approvalsTo provide Pewter to youContract (Art. 6(1)(b)). Under the PDPA: you consent by using Pewter, and we collect only what is needed to provide it
Link your public wallet address and show your wallet in the appTo provide the wallet feature you chose to useContract (Art. 6(1)(b)). Under the PDPA: consent by using the feature
Fill in your machine's country, region and city from your locationTo save you typing itConsent (Art. 6(1)(a)), given through the iOS permission prompt. You can say no and pick by hand
Check your in-app purchases and give you what you boughtTo provide subscriptions and boostsContract (Art. 6(1)(b))
Run the Daily Forge, streaks, packs and achievementsTo provide these featuresContract (Art. 6(1)(b))
Show you to other users only as an aliasTo keep identities privateContract (Art. 6(1)(b))
Keep Pewter secure, find and stop abuse and fraud, limit request rates, debug problems, keep audit logsTo protect you, other users and usLegitimate interests (Art. 6(1)(f)). Under the PDPA: legitimate interests, and a reasonable purpose
Check that Pewter is not being used in breach of sanctions or export-control rules, and respond to lawful requests from authoritiesTo follow the lawLegal obligation (Art. 6(1)(c)) and, where no obligation applies, legitimate interests (Art. 6(1)(f)). Under the PDPA: required or authorised by law
Answer your support messagesTo help youContract (Art. 6(1)(b)) or legitimate interests (Art. 6(1)(f))
Keep and improve Pewter, fix errors, and test new featuresTo make Pewter work betterLegitimate interests (Art. 6(1)(f)). Under the PDPA: legitimate interests
Use your name, only if you choose to share itTo personalise greetings and to identify your account if you contact usConsent (Art. 6(1)(a)). You can withdraw it at any time
Keep records for legal claims, accounts and auditsTo protect our legal position and meet our dutiesLegal obligation (Art. 6(1)(c)) and legitimate interests (Art. 6(1)(f))

We do not sell your personal data. We do not use it for advertising. We do not use it to build profiles to show you adverts.

Where we rely on legitimate interests, we have weighed them against your rights. You can ask us for more detail about this by writing to devs@h3ir.com.

5. Other users see only an alias

Other users see you only under an alias such as "Buyer-1234" or "Seller-5678". Your name, email and account details are not shown to them. This privacy between users does not apply to us or to authorities. We know who our users are, and we may disclose information where the law requires it.

6. Workloads that pass through our gateway

Today, Pewter does not run real customer workloads. Jobs, uptime, and delivery figures in the sandbox are simulated.

If we offer live services, you may send a workload through our gateway to compute capacity run by a third-party provider. For the content of those workloads (the data you send, the code you run, and the results), our role will be a processor. This means we handle that content on your behalf and on your instructions. You or your company will be the controller. We will offer business customers a data processing agreement for this. Our approach is:

7. Who we share data with

We share personal data only with the following, and only as needed:

RecipientWhat they doData involved
AppleVerifies Sign in with Apple, provides the private relay email, and revokes Pewter's access on request or when you delete your account. Apple also runs the App Store and TestFlight, takes payment for in-app purchases and sends us purchase records, and is a separate controller for its own dataApple user identifier, authorisation tokens, email relay data, in-app purchase records
Railway (hosting and database provider)Hosts the Pewter servers and the database, as our processorAll data described in section 3 that is stored on our servers
Cloudflare (network and security provider)Delivers and protects traffic to our website and some of our servers, as our processorIP address, request details
Blockchain network services (wallet only)When the app shows your wallet balance, your phone asks a public network service for it directly. That service sees your public address and your IP address. [CONFIRM: name the services, e.g. the public Base and Base Sepolia endpoints the server lists]Public wallet address, IP address
Google Fonts (website only)Provides the typeface that the website displays. Your browser asks Google for it, so Google receives your IP address and browser detailsIP address, browser details
Our email providerDelivers and stores email sent to and from devs@h3ir.comSupport messages, your email address
Professional advisers, insurers, and acquirersLegal, accounting and similar advice; or a buyer of our business, who would be bound to treat your data as set out hereOnly what is needed
Authorities and courtsWhere the law requires it or to protect legal rightsOnly what is needed
Third-party providers of compute and other usersOnly when live services are offered. Providers receive what they need to run a job, not your account details. Other users see your alias onlySee section 6

We do not share personal data for advertising. If we add a new recipient (such as a payment, bank or identity-check partner for live services), we will update this policy first.

8. Transfers of personal data abroad

We are based in Singapore. Our service providers may process data in other countries, including the United States. Singapore is not on the European Commission's list of countries with an adequacy decision, and some providers are in countries that are not on it either.

When we transfer personal data out of the European Economic Area, the United Kingdom, or Singapore, we make sure it stays protected. We use one or more of the following, depending on the case: an adequacy decision, the European Commission's standard contractual clauses (with the UK addendum where needed), contract terms that bind the recipient to a standard of protection comparable to the PDPA, or another transfer tool that the law recognises. You can ask for a copy of the safeguards that apply by writing to devs@h3ir.com.

9. How long we keep data

DataHow long
Account details (Apple user identifier, relay email, name, display alias)While your account is open. When you delete your account, we delete these or replace them with irreversible pseudonyms straight away
Session recordsUntil the session ends. Sessions end after 30 days of not being used, and at most after 90 days, or when you sign out or delete your account
Sandbox activity (listings, requests, offers, deals, approvals, ledger entries, agents, audit log)While your account is open. When you delete your account, personal details in them are replaced with irreversible pseudonyms. The audit log then keeps only hashes. We may keep the pseudonymised records so that service history stays intact
Machine location (country, region, city)While the listing or your account exists. When you delete your account, it is deleted or pseudonymised with your other sandbox activity [CONFIRM: engineering to confirm]
Wallet address recordsWhile the address is linked. If you remove or replace an address, it stays in your address history until you delete your account. When you delete your account, we delete or unlink your addresses in our records, except where we must keep them by law [CONFIRM: API notes say deletion "purges" addresses; confirm purge vs unlink]
In-app purchase records and boost history[CONFIRM: retention period, e.g. while your account is open and then as long as accounting and tax law require]
Daily Forge, streaks, packs and achievementsWhile your account is open. When you delete your account, we delete your Forge profile (including your time zone). The claim history keeps only a pseudonymous ID, dates, tiers and item IDs, with no name and no time zone
Server logs (IP address, time, request ID)90 days
Support messages12 months after we close the conversation
Node heartbeats from providers (live services only)14 days
Uptime measurements (live services only)13 months
Job logs (live services only)7 days
Ledger, payment-release and audit records of real money (live services only)7 years, because accounting and tax law require it
Records kept to meet a legal duty or to handle a legal claimAs long as the duty or claim lasts

Your wallet and the public blockchain

If you hold a live deal that is still open, we cannot finish deleting your account until the deal ends. Sandbox deals never block deletion. If you ask us to delete data that we must keep by law, we will tell you what we are keeping and why.

10. How we protect your data

We use measures that are suited to the risk. Right now, they include:

No system is perfectly secure, and we cannot promise that Pewter is. If you think your account has been compromised, tell us at devs@h3ir.com.

If there is a personal data breach that must be reported, we will tell the competent authority within the time that the law sets. Under the GDPR, this is within 72 hours of becoming aware of it. Under the PDPA, it is within 3 calendar days after we assess that the breach is notifiable. We will tell you without undue delay if the breach is likely to cause you serious harm or risk.

11. Your rights

Everyone

You may ask us at any time to tell you what personal data we hold about you, to correct it, or to delete it. You may also withdraw any consent you gave us.

If you are in the EU, the European Economic Area or the United Kingdom (GDPR)

You have the right to:

Where we rely on your consent, you may withdraw it at any time. This does not affect what we did before.

If you are in Singapore (PDPA)

You can ask us for access to your personal data and for information about how we have used or disclosed it in the past year. You can ask us to correct it. You can withdraw your consent to our collecting, using or disclosing your personal data. If you do, we will tell you what this means for what you can do with Pewter. For example, we cannot run your account without your Apple identifier.

If you are in California (CCPA and CPRA)

[COUNSEL: confirm the US state privacy-law wording (California and other states) for a Singapore company with US users.] If the California Consumer Privacy Act, as amended by the California Privacy Rights Act, applies to us, you have the right to know what personal information we collect, use and disclose, to ask us to delete or correct it, to opt out of the sale or sharing of your personal information, and to limit the use of sensitive personal information. You will not be treated worse for using these rights. We do not sell your personal information. We do not share it for cross-context behavioural advertising. Over the last 12 months we have not done either.

How to use your rights

Our privacy choices page explains each option step by step: https://omegacompute.com/privacy-choices.

Complaints

We would like the chance to fix a concern first, so please write to devs@h3ir.com. You also have the right to complain to a data protection authority at any time.

12. The website, cookies and analytics

The website at omegacompute.com does not set cookies of its own. It does not use analytics tools, advertising tools, social-media pixels, or tracking scripts. The website has no accounts, no web forms and no web tool for deleting data. To delete your account, use the app or email us (see https://omegacompute.com/privacy-choices).

Two outside services are involved when you visit it:

The website links to our page on X (x.com). If you follow the link, X's own policies apply.

If we add analytics or cookies later, we will update this policy and ask for your consent first where the law requires it.

13. Children

Pewter is for business use and is not for anyone under 18. [COUNSEL: the App Store age rating drafted for the US listing is 4+, which does not match "not for anyone under 18". Counsel decides which is right; the US children's-privacy position (COPPA and state laws) follows from it.] We do not knowingly collect data from children. If you think a child has given us personal data, write to devs@h3ir.com and we will delete it.

14. Automated decisions

We do not make decisions about you that are based only on automated processing and that have legal or similarly significant effects on you. We use automated security controls, such as request rate limits and ending sessions when we detect a stolen token. These do not have such effects. In the sandbox, an automated, scripted counterparty can respond to your test requests. This only affects test data.

If we add checks for live services that could lead to a person being refused access, such as sanctions screening, we will tell you, and a person will review any automated result before a refusal.

15. Apple: App Store privacy details

This section matches the privacy details we give to Apple for the Pewter app.

Tracking: none. Pewter does not track you across other companies' apps or websites. It does not use advertising identifiers. It contains no advertising or analytics tools from other companies. We do not buy data from or sell data to data brokers.

Apple categoryData typeWhat it means in PewterLinked to youUsed forUsed for tracking
Contact InfoNameYour name, only if you share it through Sign in with AppleYesApp functionalityNo
Contact InfoEmail AddressYour email, only if you share it. It may be an Apple private relay addressYesApp functionalityNo
IdentifiersUser IDYour Apple user identifier and your Pewter account IDYesApp functionalityNo
IdentifiersDevice IDA random ID the app creates and stores on your device, and your device nameYesApp functionalityNo
Financial InfoOther Financial InfoYour public wallet address, deal amounts, and the funded balance shown in your account [CONFIRM: define "funded balance"]YesApp functionalityNo
LocationCoarse LocationThe country, region and city of a seller's machineYesApp functionalityNo
User ContentOther User ContentListings, requests, deal terms, saved filters, approvals and agentsYesApp functionalityNo
PurchasesPurchase HistoryApple transaction records and renewal information for subscriptions and boostsYesApp functionalityNo
Usage DataProduct InteractionSwipes on the buyer stack, Daily Forge claims, streaks, pack openings and achievementsYesApp functionalityNo

Not collected: precise location, contacts, photos or videos, audio, health and fitness data, sensitive information, browsing history, search history, advertising data, environment scanning, customer support data in the app, and payment card or bank details. Support is a plain email link to devs@h3ir.com. Apple handles billing for in-app purchases. We receive no card or payment details.

Location. Pewter asks for your location only while you use the app, and only once. The prompt says: "Pewter uses your location once, only to fill in the country, region and city of your machine. Your exact position is never saved or sent." You can say no and pick the country, region and city by hand. You can change the permission at any time in iOS Settings.

Wallet. Pewter never holds your wallet's key or your funds. Our server stores only your public wallet address. See section 9.

Sign in with Apple. Sign in with Apple is the only way to sign in. We receive your Apple user identifier, and an email address and name only if you share them. The email may be a private relay address from Apple.

Delete your account. You can delete your account in the app: More > Settings > Delete account. You will be asked to sign in with Apple again, so we can prove that the request comes from you. We then end all your sessions, tell Apple to revoke Pewter's access to your Apple Account, and replace your personal details with irreversible pseudonyms. Audit records keep only hashes. If you cannot reach Apple's revocation, the deletion still completes. You can also remove Pewter yourself in Settings > your name > Sign in with Apple [CONFIRM: exact iOS menu path on current iOS]. If you remove Pewter there, Apple can tell us. When we get that notice, we end your sessions and erase your account, subject to section 9. Deleting your account does not delete the wallet on your phone, and it does not cancel a subscription you bought through Apple. You manage subscriptions in your Apple Account settings. [CONFIRM: both points against the shipped build]

Face ID. Face ID is handled only by iOS. We never receive biometric data.

16. Representative in the EU and the UK

We have not appointed a representative in the European Union or the United Kingdom. If you are in the EU, the EEA or the UK, you can contact us directly about anything in this policy at devs@h3ir.com.

17. Changes to this policy

We will post any change at https://omegacompute.com/policy with a new effective date. If a change is material, we will tell you in the app, or by email to the address we hold for you, before it takes effect. We will not use your data for a new purpose without telling you first and, where the law requires, asking for your consent. Your current choices are always at https://omegacompute.com/privacy-choices.

18. Contact

HEIR PTE. LTD., doing business as Omega Compute
Registered office: 32 Pekin Street, #05-01, Singapore 048762
Email for privacy requests, questions and complaints: devs@h3ir.com
Data Protection Officer (PDPA): Adhitya, at the same address
United States contact: [COUNSEL: a US contact or agent, if counsel says one is needed. None is appointed. Until then, United States users write to devs@h3ir.com.]