Data Protection and Privacy Policy

December 2025

Alpenglow Trading, LLC and its subsidiaries and affiliates (collectively, Alpenglow or we) respect the privacy of Personal Data and are committed to protecting Personal Data. This Data Protection and Privacy Policy (this Policy) describes the policies and procedures Alpenglow has implemented to protect Personal Data Processed by Alpenglow in accordance with applicable Data Protection Laws. This Policy also describes how Alpenglow collects, uses, and discloses Personal Data from your interactions with us, including when you visit Alpenglow websites and other online platforms as well as your privacy rights. This Policy does not apply to the Personal Data of Alpenglow's employees, contractors, or job applicants, which are subject to separate data protection policies.

Definitions

"Controller" means a natural or legal person, public authority, agency, or other body that, independently or jointly with others, determines the purpose and means of Processing Personal Data, as defined in Data Protection Laws.

"Data Protection Laws" means privacy laws and regulations that apply to Alpenglow's Processing of your Personal Data. This primarily includes the Regulation (EU) 2016/679 (GDPR), the Singapore Personal Data Protection Act 2012 (PDPA), the Chinese Cyber Security Law (the CS Law), the Chinese Personal Information Protection Law (PIPL), and applicable state and federal privacy laws in the United States.

"Data Subject" refers to you, as a natural person who can be identified, directly or indirectly, by reference to your Personal Data.

"Personal Data" means any information attributable to an identified or identifiable natural person (a Data Subject), as defined in Data Protection Laws.

"Process" or "Processing" means any operation or set of operations performed upon Personal Data, whether or not by automatic means, such as collecting, recording, using, organizing, structuring, storing, adapting or altering, retrieving, disclosing by transmission, disseminating or otherwise making available, aligning or combining, restricting, erasing, or purging.

Collection of Personal Data

a. Website Data

Alpenglow may collect your Personal Data on our websites. The technologies we use to track your movements around our websites may include cookies, tracking scripts and pixels, or tagging technologies, which we may employ to understand your preferences, improve your experience on our websites, etc.

Most internet browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored on your end device or a message always appears when you receive a new cookie. Further information can be found on http://www.aboutcookies.org.

b. Tracking Tools

We use tracking tools, such as Google Analytics, which generate information about your use of our websites. Such information may include a navigation path that you follow on our websites; how long you spend on our websites and subpages; the subpage from which you leave our websites; the country, region, or city from where you access our websites; returning or new visitor; and host name of the accessing computer (IP address).

Use of Personal Data

Alpenglow limits the Personal Data it collects to what is necessary. Alpenglow will only use Personal Data when Data Protection Laws allow Alpenglow to do so. Personal Data shall be Processed in a manner that is adequate, relevant, and not excessive in relation to the intended business purpose(s) of such Processing.

Depending on the nature of Alpenglow's interactions with you, we may Process your Personal Data for some or all of the following purposes:

  • To respond to your questions and requests
  • To provide you with access to certain areas and features of our websites
  • For record keeping purposes
  • For security and safety purposes, such as protecting against cyber threats
  • Detecting, investigating, or preventing fraud and other illegal activities
  • Responding to legal and regulatory compliance obligations

Privacy Rights of Data Subjects

Depending on the applicable data protection and privacy laws and regulations where you are located, you may be entitled to exercise some or all of the below Data Subject rights:

  • Request access to your Personal Data that Alpenglow holds
  • Request correction of your Personal Data that Alpenglow holds
  • Request erasure (deletion) of your Personal Data
  • Object to Processing of your Personal Data
  • Request restriction of Processing of your Personal Data
  • Request the transfer of your Personal Data
  • Withdraw consent at any time where Alpenglow is relying on consent to Process Personal Data

To make a request, please send an email to webinfo@alpenglowtrading.com or call (608) 720-7935.

Contact Information

If you have any questions about this Policy or our privacy practices, please contact us at webinfo@alpenglowtrading.com.