Terms governing participation in the Cycas Digital Assets and Fintech Compensation Survey.

These terms apply to any firm that participates in a Survey cycle by submitting employee compensation data to Cycas. A “Participant” is the firm; the Participant’s employees are not parties to these terms and do not transact with Cycas directly.

For each employee the Participant chooses to include, we collect:

• Role title (as recorded in the Participant’s HRIS)
• Level or grade (as recorded in the Participant’s HRIS)
• Geography (country; sub-national where relevant)
• Cash compensation components — base, bonus, sign-on, and other cash elements as disclosed
• Equity compensation — grant details, vesting schedule, current strike where applicable
• Token compensation — grant details, vesting schedule, underlying token, lockup terms
• Carry and deferred compensation — captured at Participant election from cycle 2 onwards; not collected in the inaugural cycle
• Other data fields the Participant elects to submit as part of extended cuts

Participants must not submit personally identifiable information about individual employees, including names, email addresses, employee IDs, national identifiers, or any free-text field that could identify an individual. Submissions containing such data will be rejected at ingestion or, where detected after upload, deleted within 24 hours and the Participant notified. The Participant warrants that all submitted data has been de-identified prior to upload.

• Access controls. Submitted data is stored under role-based access controls. Only personnel directly engaged in survey production can access raw Participant data.
• Encryption. Data is encrypted in transit (TLS) and at rest.
• No third-party sharing. We do not sell, rent, or share raw Participant data with any third party for any purpose. Aggregated survey outputs are provided only to Participants.
• Classification. Our AI classification layer runs within our infrastructure. Raw Participant data is not sent to third-party model providers.

Once data is submitted to Cycas for the purpose of producing the Survey, Cycas acts as data controller for that data, since Cycas determines the purposes and means of processing the data into Survey outputs. The Participant remains the controller of the underlying employment relationship and the source records.

Cycas processes submitted data on the legal basis of legitimate interests under Article 6(1)(f) of the UK GDPR and EU GDPR, and equivalent grounds under Singapore’s PDPA and other applicable frameworks. A balancing assessment supporting this basis is available to Participants on request.

Cross-border transfers from the UK, EEA, Switzerland, and other regulated jurisdictions to Singapore rely on appropriate safeguards, including Standard Contractual Clauses (SCCs), the UK International Data Transfer Addendum (IDTA), and equivalent mechanisms. Cycas maintains a list of categories of sub-processors (including infrastructure providers) supporting Survey production; this list is available to Participants on request.

Submitted data is used exclusively to produce the Survey’s aggregated outputs — benchmarks, percentile cuts, and the written market narrative delivered to Participants. It is not used for:

• Marketing, advertising, or lead-generation purposes
• Services provided to non-Participants
• Any purpose other than producing the Survey outputs, except where explicitly authorised by the Participant in writing

To protect Participant confidentiality, we enforce the following rules on every published cut:

• Minimum suppression threshold. No percentile cut is published unless it includes at least five incumbents drawn from at least three distinct Participants. Tail percentiles (P10, P90) and certain narrow cuts may apply higher thresholds. Cuts that fall below the applicable threshold are omitted from Participant reports.
• Organisation-weighted estimation. Percentiles are computed organisation-weighted so that no single Participant disproportionately influences any published figure.
• Disclosed sample composition. Each published cut lists the number of contributing organisations and the sample size. Participants can always see the basis for any figure.

The Survey is structured to comply with established competition-law safe-harbour principles for compensation benchmarking, including the UK Competition and Markets Authority’s September 2025 guidance on benchmarking exchanges and equivalent frameworks in other jurisdictions.

In particular:

• Submitted data is historic, not forward-looking.
• Aggregated outputs prevent identification of any individual Participant’s data, through suppression thresholds, organisation-weighted estimation, and disclosed sample composition.
• The Survey is not a venue for any agreement, understanding, or coordination among Participants on compensation, and Cycas does not facilitate any such communications.
• Participants must independently determine their own compensation strategies and decisions.

• Raw Participant uploads are retained for the duration of the current Survey cycle plus one further cycle (for comparability analysis), after which they are deleted from production systems within 90 days.
• Aggregated outputs and methodology artefacts are retained indefinitely for longitudinal analysis.
• Participants may request earlier deletion of their raw uploads at any time; contact details below.

Participants may, at any time and without penalty:

• Withdraw from the current Survey cycle prior to publication
• Request deletion of raw uploads already submitted
• Opt out of named-participant listings on Cycas marketing materials
• Request a copy of the data they submitted

Withdrawal does not entitle the Participant to a refund of participation fees already paid. Requests to exercise any of these rights should be directed to the contact address below.

Survey outputs — including market reports, percentile cuts, interactive analytics, and the written market narrative — are confidential to the receiving Participant and the Participant’s authorised internal personnel.

Outputs may not be redistributed, published, quoted publicly, or shared with third parties (including affiliates, portfolio companies, external consultants, search firms, or media) without Cycas’s prior written consent.

Reproduction of figures or analyses within the Participant’s internal compensation committee materials, board papers, and equivalent governance documents is permitted, provided the source is attributed to “Cycas Compensation Survey — Digital Assets and Fintech, [cycle year]”.

Firms participating in the inaugural cycle (“Founding Participants”) receive pricing commitments that persist for the lifetime of their continuous participation. Specifically:

• Founding Participants receive a pricing discount against list for subsequent cycles, set at our discretion.
• Founding Participants receive first access to each cycle’s outputs before access is extended to any subsequent cohort.
• Founding Participants may propose additions to the job taxonomy; we will incorporate reasonable requests into the next cycle.

A lapse in participation (non-renewal for a full cycle) terminates founding-participant status. Re-joining subsequent cycles is at the then-current rates.

We may update these Survey Terms from time to time. Material changes (affecting data handling, publication thresholds, or Participant rights) are notified to current Participants by email at least 30 days before they take effect. Minor clarifications (typography, link updates) are made without notice.

Questions about these Survey Terms, or requests to exercise any Participant right described above:

Cycas Solutions · Survey Operations
survey@cycas.cc

For data protection enquiries, including requests under applicable data protection law:
privacy@cycas.cc

These Survey Terms are governed by the laws of Singapore. Any dispute arising out of or in connection with these Terms, including any question regarding their existence, validity, or termination, shall first be addressed through good-faith negotiation between the parties for a period of thirty (30) days from written notice of the dispute.

Where a dispute is not resolved through negotiation, it shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre (SIAC) in accordance with the SIAC Rules in force at the time. The seat of arbitration shall be Singapore. The tribunal shall consist of one arbitrator. The language of the arbitration shall be English.