• 1. Introduction

UE Capital Ltd (or “UE Capital” or “we” or “us”) respects your right to privacy. The following describes the Personal Information Privacy Policy (“Policy”) that governs the collection of such data via this website and any other affiliated websites and applications. Websites operated by third parties and other organizations are not subject to this Policy. Additionally, the Policy pertains to personal information gathered during service usage or interaction, including any correspondence conducted via phone, email, or other means. The purpose of the Policy is to provide you with information regarding the nature of the data we collect, the recipients of that data, its intended purpose, the security measures in place to protect it, and your rights regarding the privacy of that data.

The term “electronic communication” refers to transmitting a text, audio, or image that may be stored in the recipient’s terminal equipment or the network until the intended recipient collects it. It comprises techniques such as instant messaging and email.

Please contact us with any inquiries or concerns regarding our utilization of your personal information.

2. What personal information does UE Capital collect and why?

The personal information that we may collect about you broadly falls into the following categories:

2.1 INFORMATION THAT YOU PROVIDE VOLUNTARILY

You must provide us with your identification, contact information, financial details, and more by completing forms or correspondence via phone, mail, electronic mail, or other means. Personal information is comprised of such data when you:

• Apply for our products or services.
• Create an account on our website.
• Subscribe to our or related third-party services or publications.
• Request marketing to be sent to you.
• Enter a competition, promotion, or survey.
• Give us some feedback.

Furthermore, specific sections of our website may request that you voluntarily provide personal information (e.g., by subscribing to our marketing communications or submitting inquiries to us). When we request your participation, we will communicate the personal information you must offer and the rationale behind that request.

2.2 INFORMATION THAT WE COLLECT AUTOMATICALLY

We may automatically collect certain information from your device when you visit our website. This information might be deemed personal information in certain nations in accordance with relevant data protection legislation.

In particular, the data we automatically gather may consist of technical information and your IP address, device type, unique device identification numbers, browser type, and broad geographic location (e.g., city or country level). We may also gather data regarding the interactions between your device and our electronic communications and website, such as the pages you visit and the links you click.

The acquisition of this data empowers us to gain a more comprehensive understanding of the individuals who access our website, their origins, and the specific content that piques their interest. This information is utilized to enhance the quality and relevance of our website for visitors and internal analytics purposes.

A portion of this data might be accumulated through cookies and analogous monitoring mechanisms. Check our Cookie Policy for comprehensive information regarding the cookies we employ and the purposes for which they are used.

2.3 INFORMATION THAT WE OBTAIN FROM THIRD-PARTY OR PUBLICLY AVAILABLE SOURCES

We may occasionally receive personal information about you from third-party sources only after confirming that such third parties have your consent or are otherwise authorized or required by law to provide us with such information.

We utilize the data obtained from these external sources to improve the quality of our services. For instance, we may curate content pertinent to the services you have received or to subjects that pique your interest.

3. Who does UE Capital share my personal information with?

We may disclose your personal information to the following categories of recipients:

3.1 To our Group of Companies, Third-Party Service Providers, and Business Partners who furnish us with data processing services (e.g., to facilitate the operation of our website, offer functionalities on it, or contribute to its security). -to these entities that process personal information for objectives outlined in this Privacy Statement or as communicated to you when we gather your personal information.

3.2 To any competent law enforcement body, regulatory, government agency, court or other third partyto which we deem disclosure to be in the following circumstances: (i) in accordance with relevant legislation or regulations; (ii) to safeguard your vital interests or those of another individual; or (iii) to exercise, establish, or defend our legal rights.

3.3 To a potential buyer(along with its representatives and consultants) regarding a suggested acquisition, merger, or purchase of a component of our enterprise, contingent upon our notifying the purchaser that your personal information shall be utilized solely for the objectives specified in this Privacy Statement.

3.4 To any other person with your consent to the disclosure.

4. Provisions for handling personal information

Whether we are permitted to collect and utilize the above-described personal information will be contingent on the nature of the information and the setting in which it is obtained.

In general, however, we will only collect personal information from you if we have your consent or if we need to perform a contract with you. We may be required by law to collect personal information from you in certain circumstances, or we may require the data to safeguard vital interests.

Suppose we are obligated to obtain your personal information to fulfill a contractual agreement with you or comply with the law. In that case, we will communicate this at the appropriate moment and explain the mandatory nature of the information request, along with the potential repercussions that may arise from your failure to comply.

Please contact us if you have any inquiries or require additional details regarding the legal grounds upon which we gather and utilize your personal information.

5 The purpose for which we will use your personal information.

5.1 SERVING YOU AS A CLIENT

Type of Data: Identity, Contact Details, National Identifier, Socio-demographic, Transactional, Financial, Contractual, Documentary Data, Communications with you.

For the purpose of:

• On-boarding you as a new client
• Setting up and providing access to your trading account
• Delivering our products and services
• Facilitating your withdrawals, deposits, and funds transfer
• Responding to your queries via chat, electronic communication, and phone

5.2 ADMINISTERING OUR OPERATIONS AND BUSINESS

Type of Data: Transactional, Financial, Contractual, Technical, Locational, Usage Data.

For the purpose of:

• Managing our risk exposure and financial position.
• Stress testing our systems and controls.
• Reviewing and improving our processes.
• Carrying out audits.

5.3 MANAGING RISK, FINANCIAL CRIME PREVENTION, RESPONDING TO REGULATORY REQUIREMENTS AND LEGAL CLAIMS

Type of Data: Transactional, Financial, Identity

For the purpose of:

• To detect, investigate, report, and seek to prevent financial crime.
• To manage risk for us and our customers.
• To be compliant with applicable laws and regulations.
• To respond to complaints and seek to resolve them.
• Assessing your profile before and during our relationship with you.
• Submitting information to regulators as necessary for investigatory purposes.

5.4 MARKETING

Type of Data: Contact, Consents, Locational, Technical, Behavioral, Communications

For the purpose of:

• Develop and carry out marketing activities.
• To provide advice or guidance about our products and services.

6 How does UE Capital keep my personal information secure?

We employ suitable organizational and technical safeguards to secure the personal information we collect and process regarding you. Our security measures are proportional to the level of risk associated with the processing of your personal information.

In particular, we:

• Preserve personally identifiable information in secure facilities and, if stored electronically, on secure servers.
• We should utilize encrypted transmission connections whenever possible.
• In addition to employing access control mechanisms and firewalls, implement authentication systems (e.g., passwords) to regulate unauthorized access to systems and data.
• Consistently assess our procedures for gathering, retaining, and processing information and tangible security measures to prevent unauthorized access to the system.
• Limit access to personal information to personnel, contractors, and agents who require that information for us to process it and are obligated to maintain strict contractual confidentiality.

UE Capital reserves the right to discipline or terminate personnel who unlawfully obtain information with malevolent intent.

7. Cookie preferences

Some of the cookies that UE Capital sets when you visit any of our websites are essential to the working functionality of the site. Without these cookies, you could not chat online, fill out a trading application, or deposit funds. Performance cookies are another type of cookies UE Capital uses to provide you with a better user experience and improve how our website’s content is presented. Third-party advertising networks also set up marketing cookies to ensure we provide targeted adverts that are more relevant to you and your interests.

8. International data transfers

We reserve the right, under specific circumstances, to transfer your personal information to a third party located in a foreign jurisdiction to continue to process it as outlined in this Privacy Statement. We will ensure that your privacy rights are adequately protected under these conditions through contractual, organizational, technical, or other lawful means. For transfers of personal information between our group companies, this includes establishing data transfer agreements that require all group companies to safeguard the personal information they process. We have similarly implemented suitable safeguards with our associates and third-party service providers; additional information is available upon request.

9. Data retention

Without further retention mandated by law, your personal information will be kept for the limited period required to fulfill the objectives outlined in this Privacy Statement. Nevertheless, we shall not retain any of your personal information after this period. Furthermore, we shall periodically review the retention of your data. We may keep an anonymized version of your personal information that, beyond a specific point in time, will no longer pertain to you.

10. Your data protection rights.

Subject to certain conditions, individuals are provided with data protection rights, including:

10.1 Right to obtain a copy of your personal information. You have the right to obtain a copy of the personal data we hold about you.

10.2 Right to rectification. You may request that we rectify any inaccurate and completely incomplete personal information. We will then correct our records and notify any third parties to whom such personal information may have been transmitted as described above.

10.3 Right to data portability. You may request a copy of all personal information you provided, after which we will transmit that data to another third party of your choice.

10.4 Right to opt out of marketing communications. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you, or for SMS communications, reply with “STOP.”

10.5 Right to withdraw consent. You may withdraw your consent to process your personal information at any time. Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your personal information is essential.

10.6 Right to object to processing. You may request that we stop processing your personal information. Please note that you may not be able to benefit from certain service features for which processing your personal information is essential.

10.7 Right to erasure. You may request that we erase your personal information, and we will comply unless there is a lawful reason for not doing so.

If you wish to exercise any of these rights, please contact us at [email protected]. Please note that you may be required to prove your identity for us to service you.

11. Updates to this Privacy Policy

This Policy may be revised periodically to reflect legal, technical, or business developments subject to change. Contingent on the magnitude of the modifications we implement, we shall employ suitable methods to notify you when our Policy is revised.

Verify the “last updated” date at the top of this Policy to determine when its most recent update occurred.