Privacy policy  (hereinafter, “the Company”) takes the security of clients’ personal data and
the storage of confidential information very seriously.

To prevent any loss, misuse, changes, or unauthorised access of information by third parties, the
Company fulfils all relevant requirements (both administrative and technical), i.e. regularly
performs checks, tests, and other essential reviews.

The Company respects your right to privacy. This Privacy Policy (hereinafter, "Policy") applies
to personal information that is collected from the Company website as well as any other
affiliated websites and applications. This Policy does not apply to websites operated by other
organisations and other third parties. This Policy also applies to personal information that is
collected when you use the Company’s products and services as well as during any
correspondence held by telephone, email, or otherwise. This Policy aims to inform you about the
type of information gathered by the Company, what it’s used for, how it’s kept secure, and what
your data privacy rights are. 

What personal information is collected by the Company and for what purposes?

The personal information that may be collected by the Company falls into the following

Information that you provide voluntarily

You can provide the Company with your personal details, contact information, and
financial data etc. by filling in forms online or by sending them by post, providing them
over the telephone, via webiste, email, or any other available method. This includes the
personal information you provide when you:

 apply for the Company’s products or services;
 create an account on the Company website;
 subscribe to the Company’s publications or those of affiliated third parties;
 agree to receive promotional materials from the Company;
 give feedback.

In addition to the above, certain parts of the Company website may ask you to provide
personal information voluntarily. The personal information that you are asked to provide,
along with the reasons for which you are asked to provide it, will be made clear to you at
the time you are asked to provide such information. 

Information that the Company collects automatically

When visiting the Company website, certain information (such as your IP address, device
type, browser type etc.) is sent from your device automatically. In some jurisdictions,
including European Union member states, this information may be classified as personal
information under standard regulations for data protection.

The Company also receives information about how your device has interacted with the
website, including the pages accessed and links followed.

Collecting this information enables the Company to conduct analyses of user and Client
requests for the purposes of improving the quality of available products and services.

Disclosure of personal information

The Company may disclose your personal information to the following categories of

 Group companies, third-party service providers, and partners who provide the
Company with data processing services (for example, to support the delivery of,
provide functionality for, or help to enhance the security of the Company website)
or who otherwise process personal information for the purposes described in this
 Any competent law enforcement body, regulatory or government agency, court,
or other third party as permitted by law.
 Any other person with your consent to the disclosure of such information.

The Company uses your personal data for the following purposes:

1. Serving you as a client
Type of data: identity (name, country of residence, address, and other similar
information); contact details (email address, telephone number, webpage, and other),
copies of national identity documents (passport, identity card, residency permit, US
residency information, and similar), financial (bank account details, bank card numbers
and holder name, documents confirming origin of capital, and other similar), political

Purpose: registering you as a new client, providing the opportunity to open a trading
account, providing the opportunity to use the Company’s products and services,
facilitating non-trading operations in accordance with the Regulations for Non-trading
Operations, and collecting information regarding the possibility that funds are owed to
the Company.

Legal basis: compliance with the Client Agreement, compliance with legal requirements.

2. Managing risk, money laundering prevention, and responding to regulatory
requirements and legal claims

Type of data: transactional, financial, identity
Purpose: compliance with applicable laws; money laundering detection, investigation,
and reporting; responding to complaints; submission of information to applicable
governmental bodies in cases where it is required by law; the collection of information
where there is a legal obligation to do so for compliance and AML purposes, such as
‘know your client’ information; information relevant to international sanctions and
restrictive measures; and information about unlawful or political activities of a potential
client, which may impact the Company’s decision to conclude an agreement with the

Legal basis: compliance with legal requirements.

3. Marketing
Type of data: contact information, consent, and correspondence.
Purpose: marketing activities and the provision of information concerning the
Company’s products and services.
Legal basis: compliance with the Client Agreement.

Clients have the following rights:

 To send a request for the correction of any inaccurate information and/or the completion
of any incomplete personal information. The Company will subsequently process the
request and notify any third parties to whom such personal information may have been
transmitted in accordance with the terms set out in this Policy.
 To opt out of receiving any marketing materials sent by the Company to clients.
 To request that the Company stop processing your personal information. Withdrawing
consent for personal data processing may prevent you from being able to access certain
products and services for which the processing of personal information is necessary.
 Consent to the processing of personal information may be withdrawn at any time. Such
withdrawal will not affect the lawfulness of processing to which consent was previously
given. Withdrawing consent may affect access to certain features of the Company’s
service for which the processing of personal information is necessary.
 To request that the Company erase all of your personal information, with which the
Company shall comply, unless there is a lawful reason for not doing so.

Company security measures

The Company applies all appropriate technical and administrative measures necessary to
protect the personal information that it collects and processes. The measures used are
designed to provide a level of security appropriate to the risk of processing personal
information. In particular, the Company:
 Stores personal data on secure servers.
 Uses encrypted transmission links in cases where it is both possible and
 Uses other safeguards: firewalls, authentication systems (e.g. passwords), and
access control mechanisms to prevent unauthorised access to systems and data.
 Regularly reviews information collection, storage, and processing practices,
including physical security measures, to guard against unauthorised access to
 Restricts access to personal information to Company employees, contractors, and
agents who need to know such information in order to process it, and who are
subject to strict contractual confidentiality obligations.

Data retention

Your personal information is only retained for as long as it is necessary to carry out the
purposes set out in this Policy (unless further retention is required by law).

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