PRIVACY POLICYPrivacy Policy

TABLE OF CONTENTS
1.

IMPORTANT INFORMATION AND WHO WE ARE ............................................................................................. 5
A.

WHO WE ARE...................................................................................................................................................... 5

B.

PURPOSE OF THIS PRIVACY POLICY.............................................................................................................. 5

C.

CONTROLLER & PROCESSOR.......................................................................................................................... 6

D.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES ....................... 7E.

THIRD-PARTY LINKS .......................................................................................................................................... 7

2.

THE DATA WE COLLECT ABOUT YOU ................................................................................................................ 7A.

APPLICATION INFORMATION .......................................................................................................................... 8

B.

TRANSACTION INFORMATION ........................................................................................................................ 8C.

VERIFICATION INFORMATION ......................................................................................................................... 8D.

AGGREGATED DATA ......................................................................................................................................... 8E.

SPECIAL CATEGORIES OF DATA ..................................................................................................................... 93.

LEGAL BASIS OF DATA PROCESSING ................................................................................................................ 94.

IF YOU FAIL TO PROVIDE PERSONAL DATA .................................................................................................... 105.

HOW ARE YOUR PERSONAL DATA COLLECTED? .......................................................................................... 10A.

DIRECT INTERACTIONS .................................................................................................................................. 10

B.

AUTOMATED TECHNOLOGIES OR INTERACTIONS ................................................................................... 10C.

THIRD PARTIES OR PUBLICLY AVAILABLE SOURCES................................................................................. 116.

HOW WE USE YOUR PERSONAL DATA ............................................................................................................ 11A.

CIRCUMSTANCES IN WHICH WE MAY USE YOUR PERSONAL DATA .................................................... 11

B.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA .............................................................. 12‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 2 of 35

Privacy Policya)Overview .................................................................................................................................................. 12b)Marketing & Promotional Offers from Us...................................................................................... 14c)

Third-Party Marketing ......................................................................................................................... 15d)Opting Out of Marketing Messages ............................................................................................... 157.

USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES ....................................................................... 158.

ANALYSIS AND TARGETING TOOLS ................................................................................................................. 17A.

GOOGLE SERVICES ......................................................................................................................................... 17

B.

GOOGLE ANALYTICS ...................................................................................................................................... 17C.

RETARGETING AND REMARKETING .............................................................................................................. 18

D.

GOOGLE CONVERSION TRACKING ............................................................................................................. 19E.

FURTHER SERVICES OF THE GOOGLE MARKETING PLATFORM ............................................................. 19

F.

FACEBOOK CUSTOM AUDIENCES ............................................................................................................... 20

G. OTHER WEB ADVERTISING PLATFORMS WE USE ...................................................................................... 21
9.

SOCIAL MEDIA PLUGINS..................................................................................................................................... 22

10.

SOCIAL MEDIA PRESENCE ............................................................................................................................. 23

A.

NOTE REGARDING OUR FACEBOOK PAGE ................................................................................................ 23

B.

NOTE REGARDING TWITTER .......................................................................................................................... 23

C.

NOTE REGARDING INSTAGRAM ................................................................................................................... 24

D.

NOTE REGARDING YOUTUBE ........................................................................................................................ 24

E.

NOTE REGARDING LINKEDIN ......................................................................................................................... 25

11.
12.

PAYMENT PROCESSING ..................................................................................................................................... 25
RECORDING OF TELEPHONE CONVERSATIONS, ELECTRONIC COMMUNICATIONS, INTERNETCONVERSATIONS (LIVE CHATS), AND MEETINGS................................................................................................ 26
13.

JOB APPLICATIONS......................................................................................................................................... 27‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 3 of 35

Privacy Policy
14.

WHERE WE KEEP YOUR PERSONAL DATA ................................................................................................... 27

15.

DISCLOSURES OF YOUR PERSONAL DATA ................................................................................................. 28

A.

Other Community Members ..................................................................................................................... 29

B.

Third Parties Providing Services to us .................................................................................................... 29

C.

To Protect the Rights of Related and Others ....................................................................................... 30

D.

Affiliates and Business Transfer ............................................................................................................... 30

16.

CHANGE OF PURPOSE.................................................................................................................................... 30

17.

INTERNATIONAL TRANSFERS OF PERSONAL DATA ................................................................................... 31

18.

DATA SECURITY ............................................................................................................................................... 31

19.

DATA RETENTION............................................................................................................................................. 32A.

HOW LONG WILL YOU USE MY PERSONAL DATA FOR? ........................................................................... 32

B.

ERASURE OF YOUR PERSONAL DATA .......................................................................................................... 32

20.

YOUR LEGAL RIGHTS ....................................................................................................................................... 32

A.

THE VARIOUS RIGHTS YOU HAVE ................................................................................................................ 32

B.

NO FEE USUALLY REQUIRED........................................................................................................................... 34

C.

WHAT WE MAY NEED FROM YOU ................................................................................................................ 34

D.

TIME LIMIT TO RESPOND ................................................................................................................................ 34

21.

RIGHT TO COMPLAIN...................................................................................................................................... 34

22.

RIGHT OF OBJECTION .................................................................................................................................... 35

23.

REVIEWING THIS POLICY................................................................................................................................ 35‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 4 of 35

Privacy Policy

PRIVACY POLICYThis Privacy Policy (“Policy”) explains the privacy practices employed by ‘FinPros Financial Ltd’(the “Company”, “we”, “our” and/or “us”) in providing services to its Clients (“Client” and/or“You”).

1.

IMPORTANT INFORMATION AND WHO WE ARE
A. WHO WE ARE

1.1.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company
registered in Seychelles with company registration number: 8429300-1, having its
registered office at CT House, Office 9A, Providence, Mahé, Seychelles.

1.2.

The Company is regulated by the Financial Services Authority (‘FSA’) of Seychelles, as a
Securities Dealer with License number: SD087.

B. PURPOSE OF THIS PRIVACY POLICY
1.3.

This Privacy Policy aims to give you information on how the Company collects andprocesses your Personal Data through your use of this website, including any data you
may provide through this website when you sign up to any of the services offered by theCompany.

1.4.

Our website is not intended for minors under the age of eighteen (18) and we do notknowingly collect data relating to minors under the age of eighteen (18).

1.5.

It is important that you read this Privacy Policy together with any other Privacy Policy orfair processing notice we may provide on specific occasions when we are collecting orprocessing Personal Data about you so that you are fully aware of how and why we areusing your data. This Privacy Policy supplements the other notices and is not intended tooverride them.

1.6.

We are a financial services provider and recognize the utmost importance of protecting
our clients’ privacy. We have policies to maintain the confidentiality and security of yournonpublic personal information. The following Policy is designed to help you understandwhat information we collect from you and how we use that information to serve youraccount(s).

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 5 of 35

Privacy Policy
1.7.

This Privacy Policy is based on data protection rules and principles derived from theapplicable laws, rules and regulations, such as:a) Article 20(1)(b) of the Constitution of the Republic of Seychelles, which provides thatevery person has a right not to be subjected without their consent or an order of theSupreme Court, to the interception of the correspondence or other means ofcommunication of that person either written, oral, or through any medium; as well as,b) the Seychelles Data Protection Act 2002 (Act 9 of 2003) ('the Act') which was enacted
in 2003 to provide individuals with privacy rights regarding the processing of Personal
Data (but which at the time of writing, has not yet entered into force) (the “Information
Protection Law”); andc) as regard Clients who are located in the European Union, and because all our Clients’
Personal Data in electronic format (e-mails, documents, databases, uploaded
batches of data, etc.) are stored on specially protected servers maintained in the
United Kingdom and/or in the European Union, the General Data Protection
Regulation (the “GDPR”) (EU) 2016/679, which entered into effect as of the 25th of May
2018.

1.8.

In line with the foregoing, for the purposes of this Privacy Policy, we follow the principles ofthe strictest and most elaborate of the above-mentioned legal instruments, i.e., the GDPR.
Even though, strictly speaking, the GDPR is not applicable to us, other than with regard to
Clients located in the European Union, we consider the GDPR as an exemplary model andguidance, as far as the privacy and data protection of our Clients is concerned.
Furthermore, as indicated further below, all your Personal Data in electronic format (emails, documents, databases, uploaded batches of data, etc.) are stored on specially
protected servers maintained by the Company or its contractors, either in the United
Kingdom and/or in the European Union, and all processing operations are, therefore,
carried out pursuant to and in accordance with the principles set out in the GDPR.

C. CONTROLLER & PROCESSOR
1.9.

In line with the foregoing, we are acting both as the ‘controller’, i.e., the person who
determines the purpose and means of Personal Data processing (this can be determinedalone, or jointly with another person/company/body), as well as the ‘processor’, i.e., theperson who carries out the actual processing of the data under the specific instructionsof the data controller, responsible for your Personal Data.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Privacy Policy
D. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
1.10.

It is important that the Personal Data we hold about you is accurate and current. Pleasekeep us informed if your Personal Data change during your relationship with us.

E. THIRD-PARTY LINKS
1.11.

Please note that our website may include links to third-party websites, plug-ins andapplications. Clicking on those links or enabling those connections may allow third parties
to collect or share data about you.

1.12.

We do not control these third-party websites and are not responsible for their privacy
statements. When you leave our website, we encourage you to read the Privacy Policy of
every website you visit.

2.

THE DATA WE COLLECT ABOUT YOU

2.1‘Personal Data’ as defined in the GDPR means any information relating to an identified or
identifiable natural person; a natural person is considered as being identifiable, directly
or indirectly, in particular by means of an identifier such as a name, an identification
number, location data, an online identifier or one or more special characteristics
expressing the physical, physiological, genetic, mental, economic, cultural or social
identity of this natural person can be identified. This includes all information about youridentity such as your name, your e-mail address or postal address, your customer
number and online identifiers. Information that cannot be linked to your identity (such as
the registration number of online users), on the other hand, is not personally identifiable
information. In addition, Personal Data do not include data where the identity has been
removed (‘anonymized data’).

2.2

You can use our online and mobile services without revealing your identity and without
providing any Personal Data. When using our website(s) and/or online trading platforms,
our client portal, the apps and some services of our website(s) and apps, however, willcollect your personal information.

2.3

We have grouped together the different kinds of Personal Data about you, which we may
collect, use, store and transfer, as follows:‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Privacy Policy
A. APPLICATION INFORMATION
2.4

You can register as a user of our online and mobile services. To do this you must enter thedata requested, for example name, address and e-mail address. We also record the date
and time of registration and the IP address. As part of the registration process, we obtainyour consent regarding the use of the data. Such personal information, which you provide
to us in your account opening application form or registration, such as name, address,
date of birth, email address, income and income source etc. are used in order to facilitate
the evaluation of your application. The information provided is also used for the purposesof communicating with you via telephone, e-mail or chat.

2.5

The legal basis for the processing of such data for registration is Art. 6(1)(a) GDPR. Insofar
as you register for the fulfilment or initiation of a contract with us, the legal basis for theprocessing of the data is additionally Art. 6(1)(b) GDPR.

2.6

Registration is required to fulfil or initiate a contract with us for certain services.

2.7

The data will be stored by us for as long as necessary to fulfil the contract. In addition, westore these data for the fulfilment of post-contractual obligations and due to commercial
and tax retention periods for the statutory period. This retention period is usually five (5)years at the end of the respective calendar year.

B. TRANSACTION INFORMATION
2.8

Information about the anticipated volume and value of your transactions with us andincome information provided in order to enable the construction of your economic profile.

C. VERIFICATION INFORMATION
2.9

Information necessary to verify your identity, such as an identification card (ID), passport
or driver’s license. This also includes background information the Company receives
about you from public records or from other entities not affiliated with the Company.

D. AGGREGATED DATA
2.10

We also collect, use and share ‘Aggregated Data’ such as statistical or demographic data
for any purpose. Aggregated Data may be derived from your Personal Data, but is notconsidered Personal Data per se, as these data does not directly or indirectly reveal youridentity.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 8 of 35

Privacy Policy
2.11

For example, we may aggregate your ‘Usage Data’ (i.e., data is collected on what the user
is doing at his/her electronic terminal/device) to calculate the percentage of users
accessing a specific website feature. However, if we combine or connect Aggregated
Data with your Personal Data so that it can directly or indirectly used to identify you, wetreat the combined data as Personal Data, which will be used in accordance with thisPrivacy Policy.

E. SPECIAL CATEGORIES OF DATA
2.12

We do NOT collect any ‘Special Categories of Personal Data’ about you (this includes
details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual
orientation, political opinions, trade union membership, information about your healthand genetic and biometric data).

2.13

We do not collect any information about criminal convictions and offences, except, aspart of our customer due diligence (‘KYC – Know Your Customer’), where such information
is publicly available.

3.

LEGAL BASIS OF DATA PROCESSING

3.1

Insofar as we obtain consent for the processing of your Personal Data, Art. 6(1) lit. (a) GDPR
serves as the legal basis for data processing.

3.2

Insofar as your Personal Data is processed because this is necessary to fulfil a contract orin the context of a contract-like relationship with you, Art. 6(1) lit. (b) GDPR serves as thelegal basis for data processing.

3.3

Insofar as we process your Personal Data in order to fulfil a legal obligation, Art. 6(1) lit. (c)GDPR serves as the legal basis for data processing.

3.4

As a legal basis for the data processing, Art. 6(1) lit. (f) GDPR applies if the processing ofyour Personal Data is necessary to safeguard the legitimate interests of our Company ora third party and your interests, fundamental rights and fundamental freedoms do not
require the protection of your Personal Data.

3.5

As part of this Privacy Policy, we will always state the legal basis on which we base theprocessing of your Personal Data.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 9 of 35

Privacy Policy
4.

IF YOU FAIL TO PROVIDE PERSONAL DATA

4.1

Where we need to collect Personal Data by law, or under the terms of a contract that wehave with you, and you fail to provide such data when requested, we may not be able toperform the contract we have or are trying to enter into with you.

4.2

In this instance, we may have to cancel the contractual or pre-contractual relationshipyou have with us, but we will notify you if this is the case at the time.

5.

HOW ARE YOUR PERSONAL DATA COLLECTED?

5.1

We use different methods to collect data from and about you, including through:A. DIRECT INTERACTIONS
5.2

5.3

You may give us your Personal Data by filling in forms or by corresponding with us by post,phone, and email or otherwise. This includes Personal Data you provide when you:•

apply for our products or services;•

create an account on our website;•

subscribe to our service or publications;•request marketing to be sent to you;•enter a competition, promotion or survey; or•give us some feedback.

The legal basis for the processing of these data is Art. 6(1)(f) GDPR. At the same time, theabove-mentioned purposes justify the legitimate interest within the meaning of Art. 6(1)(f)General Data Protection Regulation (GDPR).

B. AUTOMATED TECHNOLOGIES OR INTERACTIONS
5.4

Each time you access our online and mobile services, we collect the following information
about the device you are using: the IP address, the request from your browser, and thedate and time of this request. In addition, the status and the amount of data transferred
are recorded as part of this request. We also collect product and version information‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 10 of 35

Privacy Policy
about the browser used and the operating system of the device, as well as the Internet
service provider. We continue to track which website accessed the service. We collectsuch technical data by using cookies, server-logs and other similar technologies (seefurther below: ‘Use of Cookies and Other Tracking Technologies’).
5.5

While such technical data, as such, are not considered Personal Data per se, as these data
do not directly or indirectly reveal your identity, we may combine or connect suchtechnical data with your Personal Data so that it can directly or indirectly identify you. In
these circumstances, we treat the combined data as Personal Data, which will be used
and/or processed in accordance with this Privacy Policy.

5.6

The legal basis for the processing of these data is Art. 6(1)(f) GDPR.

5.7

We process such data so that the content, for example the website, can be displayed onyour device. In addition, we use the data for the operation of the online and mobile
services and to detect and eliminate errors, to determine the utilization of our online andmobile services and to make adjustments or improvements.

5.8

At the same time, these purposes justify the legitimate interest within the meaning of Art.
6(1)(f) General Data Protection Regulation (GDPR).

5.9

The IP address of your device will be stored only for the time of use of the online or mobile
services and then deleted or shortened. These data are stored for a limited period of time(see further below).

C. THIRD PARTIES OR PUBLICLY AVAILABLE SOURCES
5.10

We may receive Personal Data about you from various third parties and public sources,
for instance, from analytics providers, such as Google, some of whom may be basedoutside the EU (see further below: ‘Use of Cookies and Other Tracking Technologies’).

6.

HOW WE USE YOUR PERSONAL DATA
A. CIRCUMSTANCES IN WHICH WE MAY USE YOUR PERSONAL DATA

6.1

We will only use your Personal Data when the law allows us to. Most commonly, we will use
your Personal Data in the following circumstances:‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 11 of 35

Privacy Policy•

Where we need to perform the contract we are about to enter into or have enteredinto with you.

•

Where it is necessary for our legitimate interests (or those of a third party) and yourinterests and fundamental rights do not override those interests.

•
6.2

Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your Personal Data,
other than in relation to sending third party direct marketing communications to you via
email or text message.

6.3

You have the right to withdraw consent to marketing at any time by contacting us.

B. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATAa) Overview
6.4

We have set out below, in a table format, a description of all the ways we plan to use your
Personal Data, and which of the legal bases we rely on to do so. We have also identified
what our legitimate interests are where appropriate.

6.5

Note that we may process your Personal Data for more than one lawful ground, dependingon the specific purpose for which we are using your data.

6.6

Please contact us if you need details about the specific legal ground we are relying on toprocess your Personal Data where more than one ground has been set out in the tablebelow.

Purpose/Activity

Type of data

Lawful basis for processing
including basis of legitimate
interest

To register you as a new Client(a) Identity

Performance of a contract with you(b) Contact details(c) Proof of address
document‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 12 of 35

Privacy Policy

Purpose/Activity

Type of data

Lawful basis for processing
including basis of legitimate
interest

To process and deliver your(a) Identity(a) Performance of a contract with youorder including:(a) Manage payments, fees andcharges(b) Collect and recover money
owed to us(b) Contact details(c) Proof of address
document(b) Necessary for our legitimate
interests (to recover debts due to us)(d) Transaction(e) Marketing andCommunications

To manage our relationship with (a) Identity
you which will include:(a) Notifying you about changes
to our terms or privacy policy(b) Asking you to leave a review
or take a survey(a) Performance of a contract with you(b) Contact details(c) Proof of address
document(d) Transaction(e) Marketing andCommunications

To administer and protect ourbusiness and this website(including troubleshooting, data
analysis, testing, system(b) Necessary to comply with a legal
obligation(c) Necessary for our legitimate
interests (to keep our records updated
and to study how customers use our
products/services)(a) Identity(a) Necessary for our legitimate(b) Contact details

interests (for running our business,(c) Technicalmaintenance, support, reporting

provision of administration and IT
services, network security, to prevent
fraud and in the context of a businessand hosting of data)

reorganization or group restructuring
exercise)(b) Necessary to comply with a legal
obligation

To deliver relevant website
content and advertisements toyou and measure or understand(a) Identity

Necessary for our legitimate interests(b) Contact details(to study how Clients use ourthe effectiveness of the(c) Profile

advertising we serve to you(d) Usage

products/services, to develop them, togrow our business and to inform ourmarketing strategy)‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 13 of 35

Privacy Policy

Purpose/Activity

Type of data

Lawful basis for processing
including basis of legitimate
interest(e) Marketing andCommunications(f) Technical

To use data analytics to
improve our website,
products/services, marketing,(a) Technical

Necessary for our legitimate interests(b) Usage(to define types of Clients for our
products and services, to keep ourClients relationships andwebsite updated and relevant, toexperiencesdevelop our business and to inform ourmarketing strategy)

To make suggestions andrecommendations to you about
goods or services that may beof interest to you(a) Identity

Necessary for our legitimate interests(b) Contact details(to develop our products/services and(c) Technicalgrow our business)(d) Usage(e) Profileb) Marketing & Promotional Offers from Us
6.7

We strive to provide you with choices regarding certain Personal Data uses, particularlyaround marketing and advertising.

6.8

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view onwhat we think you may want or need, or what may be of interest to you. This is how we
decide which products, services and offers may be relevant for you.

6.9

You will receive marketing communications from us, if you have requested informationfrom us or purchased services from us or if you provided us with your details when you
entered our website for the purpose of receiving information and, in each instance, if you
have not opted out of receiving that marketing.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 14 of 35

Privacy Policyc) Third-Party Marketing
6.10

We will get your express opt-in consent before we share your Personal Data with any
company outside our group of companies for direct marketing purposes.

d) Opting Out of Marketing Messages
6.11

You can ask us or third parties to stop sending you marketing messages at any time bycontacting us with your request.

7.

USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

7.1

We use ‘cookies’ and other tracking technologies to collect certain information about
your browser and related activities on our website(s) and online trading platforms. These
are small text files that are stored on an electronic device to facilitate certain settings anddata for sharing with us online about your browser and activity on our website(s) andtrading platforms.

7.2

A cookie usually contains the name of the domain from which the cookie file was sent, as
well as information about the age of the cookie and an alphanumeric identifier.
Depending on content and storage duration, there are different types of cookies. Most of
the cookies we use are so-called ‘session cookies’, which are deleted when you end yourbrowser session. In addition, there are some long-lasting cookies by which we are able torecognize you as a visitor. Many cookies come directly from us, in addition, the storageand evaluation of individual cookies come from service providers (so-called ‘third-party
cookies’).

7.3

In addition, our website(s), HTML emails and certain third party service providers may also
use other tracking technologies, such as ‘flash cookies’, ‘web beacons’ or ‘pixels’ and/or
other local storage technologies to help users access their Client’s accounts seamlessly
and save their account settings to their browsers. These are typically small transparent
images that provide us with statistics, for similar purposes as cookies. They are often usedin conjunction with cookies, though they are not stored on your computer in the sameway. As a result, if you disable cookies, web beacons may still load, but their functionality
will be restricted.

7.4

We inform you about the use of cookies and such other tracking technologies in advance,with a corresponding note on a banner.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 15 of 35

Privacy Policy
7.5

Some cookies are technically required in order to enable you to use our online and mobile
services. These cookies allow us to collect and store the following data:

7.6•

Language settings;•

Search settings;•

Contents of an online form;•

Information for identifying or authenticating the user;•

Information to identify the web browser and the corresponding settings;•

Information to verify our Client’s identity to ensure their Personal Data protection;•

Information to remember each Client’s individual preferences.

In addition, on our website(s) and trading platforms, we use cookies that allow an analysisof your user behavior, so-called ‘analysis cookies’. These cookies allow us to collect andstore the following data:•

Frequency of page views•

Searches•

Use of Internet page functions

7.7

Your data collected by means of cookies are ‘anonymized’ so that the data cannot bematched to the respective user.

7.8

The legal basis for the processing of data by means of cookies is Art. 6(1)(f) GDPR.

7.9

Cookies allow us to recognize your computer and make any presets available
immediately. Cookies help us to improve the online offer and offer you a better and moreuser-friendly service. The use of cookies is necessary to make the use of our online offers
easier. Some features can only be offered through the use of cookies. This concerns thesearch, online forms, customer account, shopping cart and notepad.

7.10

We use analysis cookies to improve and optimize the quality of our online offers and theircontent.

7.11

At the same time, these purposes justify the legitimate interest within the meaning of Art.
6(1)(f) General Data Protection Regulation (GDPR).

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Privacy Policy
7.12

The technically necessary cookies we use are so-called ‘session cookies’, which areautomatically deleted after the end of the browser session. The remaining cookies are
stored on your computer. You can delete these saved cookies yourself at any time. Mostbrowsers are also set to accept cookies automatically. However, you can disable thestorage of cookies or set your browser to notify you when cookies are sent. Please notethat you may be limited or unable to use our online service if you refuse to accept cookies.

7.13

For more details on how we use cookies and/or other storage/tracking technologies,
which cookies and other storage/tracking technologies we use and how to manage
cookies and/or the other storage/tracking technologies we use, please consult our‘Cookies Policy’.

8.

ANALYSIS AND TARGETING TOOLS
A. GOOGLE SERVICES

8.1

On our website, we use various services provided by Google Ireland Limited, Gordon
House, Barrow Street, Dublin 4, Ireland (hereinafter referred to as "Google").

8.2

For more information about Google services, please visit
http://www.google.com/privacy/ads/.

B. GOOGLE ANALYTICS
8.3

We use Google Analytics for statistical analysis. Google Analytics is a web analytics
service provided by Google LLC., 1600 Amphitheater Parkway, Mountain View, CA 94034,
USA ("Google"). Google Analytics uses so-called "cookies", text files that are stored on yourcomputer and that allow an analysis of the use of the website by you. The information
generated by the cookie about your use of this website is usually transmitted to a Google
server in the USA and stored there. However, if IP anonymization is activated on thiswebsite, your IP address will be shortened by Google beforehand within member states of
the European Union or other parties to the Agreement on the European Economic Area.
Only in exceptional cases will the full IP address be sent to a Google server in the US andshortened there. On behalf of the operator of this website, Google will use this information
to evaluate your use of the website, to compile reports on website activity and to provide
other services related to website activity and Internet usage to the website operator. The
IP address provided by Google Analytics as part of Google Analytics will not be mergedwith other Google data. You can prevent the storage of cookies by using a corresponding‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Privacy Policy
setting on your browser software; however, please note that if you do this, you may not beable to use all the features of this website to the fullest extent possible. In addition, you
may prevent the collection by Google of the data generated by the cookie and related toyour use of the website (including your IP address) as well as the processing of these data
by Google by downloading and installing the browser plug-in available under thefollowing link: http://tools.google.com/dlpage/gaoptout?hl=de/
8.4

For more information, see http://tools.google.com/dlpage/gaoptout?hl=de/ or
http://www.google.com/intl/de/analytics/privacyoverview.html (general information
about Google Analytics and privacy). We point out that on our website(s), Google
Analytics was extended under the code "anonymizeIp ();" in order to anonymize the IP
addresses, whereby the last octet is deleted.

C. RETARGETING AND REMARKETING
8.5

Retargeting or remarketing refers to technologies in which users who have previously
visited a certain website are shown appropriate advertising even after leaving thiswebsite. For this purpose, it is necessary to recognize Internet users beyond their own
website, for which purpose cookies of the corresponding service providers are used. In
addition, the previous usage behavior is considered. For example, if a user views certain
products, they may later display these or similar products as advertisements on otherwebsites. It is personalized advertising that is adapted to the needs of each user. It is notnecessary for this personalized advertisement to be identified beyond the recognition of
the user. The data used for the retargeting or remarketing will therefore not be mergedwith other data.

8.6

We use such technologies to display ads on the Internet. We use third-party providers todeliver such ads. We use, among other things, offers from Google, which allows anautomatic display of interesting products for the Internet user. This function is
implemented by ‘cookies’. For more information about this technology, see
https://policies.google.com/privacy?gl=de
under
the
following
URL:
https://policies.google.com/privacy?hl=de. The installation of cookies for Google
Remarketing and Google AdWords Conversion Tracking can be prevented by setting therespective
browsersoftwarebyaccessingthefollowing
website:http://www.google.com/policies/privacy/ads/ and changing the corresponding setting.

8.7

We use Google Retargeting Tags, Appnexus and We use Google Retargeting Tags,
Appnexus and Performance Profiles to promote our services and products. The‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Privacy Policy
retargeting JavaScript codes implemented on our website(s) store a cookie on the user's
computer for the purpose of retargeting. At a later date, the user will be provided with ourbanners or text ads, provided that the user acts on Google Search websites as well as
Google's Display Networks, Appnexus and Performance Profiles. All data is recorded
anonymously so that it is not possible to draw any conclusions about specific persons.
Users can opt out of retargeting functionality by modifying the Google Remarketing Tags
display or disabling retargeting. Alternatively, users may disable the use of third-party
cookies by using the network advertising initiative's opt-out page or object to each
network individually.

D. GOOGLE CONVERSION TRACKING
8.8

We also use Google's Conversion Tracking in this context. When you click on an ad served
by Google, a 30-day conversion-tracking cookie will be placed on your device. These
cookies are not for personal identification. The information gathered using the conversion
cookie is used to generate conversion statistics for Google Ads advertisers.

8.9

The legal basis for this data processing is legitimate interest pursuant to Art. (6)(1)(f)
GDPR.

8.10

You can disable Google interest-based ads on your browser by turning off
http://www.google.com/settings/ads or opting out ate the following URL:
http://www.aboutads.info/choices/.

E. FURTHER SERVICES OF THE GOOGLE MARKETING PLATFORM
8.11

In addition, our website(s) use(s) further services of the Google Marketing Platform(previously “Google doubleclick”). These services use cookies to serve ads that are
relevant to users, to improve campaign performance reports or to prevent a user fromreceiving ads multiple times.

8.12

Google uses a cookie ID to record which ads are played in which browser and thus
prevents them from being displayed multiple times. In addition, Google can use cookie
IDs to track what are known as conversions, i.e. whether a user sees an advertisement andlater goes to the advertiser's website and buys something there. According to Google,
such cookies do not contain person information.

8.13

Your browser automatically establishes a direct connection to the Google server. We haveno influence on the extent and further use of the data collected through the use of this‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 19 of 35

Privacy Policy
tool by Google. According to Google, through the involvement of these services, Google
receives the information that you have accessed the relevant part of our website or
clicked on an ad from us. If you are registered with a service of Google, Google can assign
the visit to your user account. Even if you are not registered with Google or have not logged
in, there is a chance that the provider will find out and store your IP address.
8.14

In addition, the Google cookies allow us to understand whether you are performing certain
actions on our website after you have viewed or clicked on one of our ads on Google oron another platform (Conversion Tracking) (“Floodlight”). Google uses this cookie tounderstand the content with which you have interacted on our web sites so that it canlater send you targeted advertising.

8.15

You can prevent the tracking process by setting your browser software accordingly (e.g.
third party cookies disabled), deactivate the cookies for conversion tracking by blocking
cookies from the domain www.googleadservices.com in your browser settings, at
www.google.com/settings/ads, for interest-based ads of the providers that are part of the
About Ads self-regulatory campaign, via the link http://www.aboutads.info/choices or thelink http://www.google.com/settings/ads/. We point out that in this case you may not beable to use all the features of this offer in full.

8.16

For more information about the Google Marketing Platform, please visit
https://marketingplatform.google.com/. You can also find more information from the
Network Advertising Initiative (NAI) at http://www.networkadvertising.org/.

8.17

The legal basis for the data processing is your consent pursuant to Art. (6)(1)(a) GDPR.

F. FACEBOOK CUSTOM AUDIENCES
8.18

Our website(s) use(s) the "Custom Audiences" remarketing feature of Facebook Inc., 1601
S. California Ave, Palo Alto, CA 94304, USA (hereinafter referred to as ‘Facebook'"). This
allows users of the website to be shown interest-based advertisements ("Facebook Ads")
as part of their visit to the social network Facebook or other websites that also use theprocess. We are interested in showing you advertisements that are of interest to you inorder to make our online offers more interesting to you.

8.19

The legal basis for the processing of your data is legitimate interest pursuant to Art.
6(1(1)(f) GDPR.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 20 of 35

Privacy Policy
8.20

The use of Custom Audience means your browser automatically establishes a directconnection to the Facebook server. We have no influence on the extent and further use of
the data collected through the use of this tool by Facebook and therefore inform you that,
according to our knowledge: By integrating Facebook Custom Audiences, Facebook
receives the information that you have accessed our website or have clicked on an adfrom us. If you are registered with a service of Facebook, Facebook can assign the visit toyour Facebook account. Even if you are not registered with Facebook or have not logged
in, there is a chance that the provider will process your IP address and other identifying
features.

8.21

Disabling the "Facebook Custom Audiences" feature is available to logged-in users at
https://www.facebook.com/settings/?tab=ads#.

8.22

For more information about data processing through Facebook, please see:https://www.facebook.com/about/privacy.

G. OTHER WEB ADVERTISING PLATFORMS WE USE
8.23

Other web advertising platforms we use include 3LIFT, Adroll, bidswitch, Bing, Criteo,
OpenX, Outbrain, Taboola, Yahoo and Yandex. These web-advertising platforms display
boxes of links to our website(s) within other websites.

8.24

These web advertising platforms use cookie IDs to serve ads that are relevant to users, toimprove campaign performance reports or to prevent a user from receiving ads multiple
times. In addition, these web advertising platforms can use cookie IDs to track what are
known as conversions, i.e. whether a user sees an advertisement and later goes to theadvertiser's website and registers there. According to our information, such cookies do notcontain personal information.

8.25

Your browser automatically establishes a direct connection to the servers of these webadvertising platforms and we have no influence on the extent and further use of the datacollected through the use of these tools. According to our understanding, through the
involvement of these services, these web-advertising platforms receive the informationthat you have accessed the relevant part of our website or clicked on an ad from us. If you
are registered with a service of these web-advertising platforms, they can assign the visit
to your user account. Even if you are not registered with these web-advertising platformsor have not logged in, there is a chance that the provider will find out and store your IP
address.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 21 of 35

Privacy Policy
8.26

The legal basis for the data processing is your consent pursuant to Art. (6)(1)(a) GDPR.

8.27

You can prevent the tracking process by setting your browser software accordingly (e.g.
third party cookies disabled), deactivate the cookies for conversion tracking by blocking
cookies from the domains of the above-mentioned web advertising platforms in yourbrowser settings and for interest-based ads of the providers that are part of the About
Ads self-regulatory campaign, via the link http://www.aboutads.info/choices. We pointout that in this case you may not be able to use all the features of the offers displayed onthese web-advertising platforms in full.

9.

SOCIAL MEDIA PLUGINS

9.1

Our website(s) use(s) the Facebook social media plug-in of Facebook Inc., 1601 S.
California Ave, Palo Alto, CA 94304, USA (hereinafter referred to as "Facebook").

9.2

An overview of Facebook plug-ins can be found at the following URL:
http://developers.facebook.com/docs/plugins; you can find further information on
Facebook's Privacy Policy at the following link: www.facebook.com/policy.php.

9.3

Facebook may receive the information that you have accessed the corresponding
website of our online service and possibly interacted with the plug-in. By activating theplug-in, your personal data will be saved and sent to Facebook in the USA.

9.4

We have no influence on the collected data and data processing operations, nor are weaware of the full extent of data collection, the purpose of the processing, or the retention
periods. We also have no information on how to delete the data collected by Facebook.

9.5

As far as we know, Facebook stores the data collected about you as usage profiles anduses them for purposes of advertising, market research and/or tailor-made website
design. Such an evaluation is carried out in particular (also for non-logged-in users) forthe presentation of needs-based advertising and to inform other users of the social
network about your activities on our website. You have a right to object to the formationof these user profiles, whereby you must exercise this right to Facebook.

9.6

Through the plug-ins, we offer you the opportunity to interact with the social networks andother users, so that we can improve our offer and make it more interesting for you as a
user.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Privacy Policy
9.7

The legal basis for the use of the plug-ins is legitimate interest pursuant to Art. 6(1)(f)
GDPR.

9.8

You can completely prevent the plug-ins from being loaded using add-ons for yourbrowser, so-called script blockers.

10.

SOCIAL MEDIA PRESENCE

A. NOTE REGARDING OUR FACEBOOK PAGE
10.1

Accessing https://www.facebook.com/finproscom/ will take you to our page on the
Facebook.com social network of Facebook Ireland Ltd, 4 Grand Canal Square, Grand
Canal Harbour, Dublin 2 Ireland (hereinafter referred to as "Facebook"). If you visit ourpage, Facebook collects data and processes it in the US, if necessary.

10.2

This also happens if you yourself are not a registered user of Facebook or simply have notlogged in to your Facebook account. According to information provided by Facebook, thedata collected includes, among other things, the IP address, operating system
information, hardware versions and browser type, data collected from Facebook cookies
about your user behavior, and other technical data.

10.3

Please refer to the Facebook Privacy Policy, which you can access here:
https://www.facebook.com/privacy/explanation. You can also find information fromFacebook about cookies on https://www.facebook.com/policies/cookies.

B. NOTE REGARDING TWITTER
10.4

We operate the Twitter account https://twitter.com/fin_pros on the short message
service, Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, (hereinafterreferred to as "Twitter"). The body responsible for the data processing of persons living
outside of the United States is Twitter International Company, One Cumberland Place,
Fenian Street, Dublin 2 D02 AX07, Ireland.

10.5

When you use Twitter, your personal data are collected, transmitted, stored, disclosed andused by Twitter, transmitted, stored and used wherever you reside in the United States,
Ireland and any other country in which Twitter operates.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 23 of 35

Privacy Policy
10.6

We have no influence on the processing of the collected data, as it is performed solely by
Twitter. Information about which data are processed by Twitter and used for which
purposes can be found in the Twitter Privacy Policy: https://twitter.com/privacy.

C. NOTE REGARDING INSTAGRAM
10.7

We run the Instagram account https://www.instagram.com/finprosofficial/ on the social
network Instagram, which is part of Facebook Ireland Ltd, 4 Grand Canal Square, Grand
Canal Harbour, Dublin 2 Ireland (hereinafter referred to as "Instagram").

10.8

If you visit our account, data will be collected from Instagram and processed in the US, if
necessary. This also happens if you yourself are not a registered user of Instagram or havenot logged in to your Instagram account.

10.9

We have no influence on the processing of the collected data, as it is performed solely byInstagram. According to information provided by Instagram, the data collected includes,
among other things, the IP address, operating system information, hardware versions andbrowser type, data collected from Instagram cookies about your user behavior, and othertechnical data. Please refer to the Instagram Privacy Policy, which you can access here:
https://help.instagram.com/519522125107875?helpref=page_content.

D. NOTE REGARDING YOUTUBE
10.10

We operate the following YouTube Channel on the YouTube video platform:
https://www.youtube.com/channel/UCTOjXmYH3G3PxC-zVGx4nqw, which is part ofYouTube LLC, 901 Cherry Ave., San Bruno, CA 94066 USA (hereinafter referred to as"YouTube").

10.11

If you visit our channel, data will be collected from YouTube and processed in the US, if
necessary. This also happens if you yourself are not a registered user of YouTube or havenot logged in to your YouTube account.

10.12

We have no influence on the processing of the collected data, as it is performed solely by
YouTube. According to information provided by YouTube, the data collected includes,
among other things, the IP address, operating system information, hardware versions andbrowser type, data collected from YouTube cookies about your user behavior, and othertechnical data.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 24 of 35

Privacy Policy
10.13

Please

refer

to

the

YouTubePrivacy

Policy,

which

you

can

accesshere:

https://policies.google.com/privacy.

E. NOTE REGARDING LINKEDIN
10.14

We run the LinkedIn account https://www.linkedin.com/company/finproscom on thesocial network LinkedIn, which is operated by LinkedIn Corporation, 1000 W. Maude Avenue,
Sunnyvale, CA 94085, USA (hereinafter referred to as "LinkedIn").

10.15

If you visit our account, data will be collected by LinkedIn and processed in EU and in theUS, if necessary. This also happens if you yourself are not a registered user of LinkedIn or
have not logged in to your LinkedIn account.

10.16

We have no influence on the processing of the collected data, as it is performed solely by
LinkedIn. According to information provided by LinkedIn, the data collected includes,
among other things, log-ins, cookies, device information and internet protocol (“IP”)
addresses to identify you and log your user behavior, and other technical data. Please
refer
to
the
LinkedInPrivacy
Policy,
which
you
can
accesshere:
https://www.linkedin.com/legal/privacy-policy and to the LinkedIn Cookie Policy, which
you can access here: https://www.linkedin.com/legal/cookie-policy.

11.

PAYMENT PROCESSING

11.1.

Depending on the chosen payment method, the payment processing for orders may takeplace through the involvement of Payment Service Providers (“PSPs”) a service provider.
Payment Initiation Service Providers (“PISPs”) in the case of open banking.

11.2.

When paying by credit card, your necessary data such as name, address and thepurchase data will be forwarded to the respective credit card company.

11.3.

If you pay via PayPal, you will be redirected to PayPal's website via a link. Your personal
data will be processed. This data relates to your name, your address, your e-mail address,
any telephone numbers and account or credit card information. Please refer to theGeneral Terms and Conditions, Terms of Use and Privacy Policy of PayPal (Europe) S.à.r.l.
et Cie, SCA, 22-24 Boulevard
http://www.paypal.com/.

11.4.

Royal,

L-2449Luxembourg

on

the

website:The legal basis for the payment processing is Art. (6)(1)(b) GDPR. The processing of yourpersonal data is required to fulfil the contract with you.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 25 of 35

Privacy Policy
11.5.

The data will be stored by us for as long as necessary to fulfil the contract. In addition, westore this data for the fulfilment of post-contractual obligations and due to commercial
and tax retention periods for the statutory period. This retention period is usually 5 years
at the end of the respective calendar year.

12.

RECORDING OF TELEPHONE CONVERSATIONS, ELECTRONICCOMMUNICATIONS, INTERNET CONVERSATIONS (LIVE CHATS), AND
MEETINGS

12.1.

We are required by law to record and maintain for a minimum period of five (5) years
from the date of the recording, all telephone conversations, electronic messaging, emails, internet conversations (chat), meetings and other communications we have withyou in the course of us providing our services to you.

12.2.

A copy of any such recordings will be available to you on request for a minimum periodof five (5) years from the date of the recording.

12.3.

Any recordings shall be and shall remain our sole property and will be accepted by you
as conclusive evidence of their content as recorded by us. You agree that we may delivercopies of transcripts of such recordings to any court, regulatory or government authority,
including without limitation, in connection with any dispute, which may arise between you
and us.

12.4.

However, technical reasons may prevent us from recording a conversation, andrecordings or transcripts made by us will be destroyed in accordance with our normal
practice. Consequently, you should not rely on such recordings to be available.

12.5.

You have the right to withdraw your consent in relation to the recording of telephone
conversations, electronic messaging, e-mails, internet conversations (chat), meetingsand other communications we have with you, by informing us in writing.

12.6.

However, as the latter is a regulatory requirement, in case you refuse or revoke yourconsent, we may be unable to provide our services to you; thus, your access and/or useof our services may be restricted or terminated.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 26 of 35

Privacy Policy
13.

JOB APPLICATIONS

13.1.

If you apply via the FinPros application portal or form or otherwise for a position with us
and send us application documents, we will process the personal data you provide in thiscontext only for the purpose of the application process.

13.2.

Insofar as you have applied for an advertised position, the documents will be
automatically deleted twelve (12) months after completion of the application procedure,
provided deletion does not conflict with our legitimate interests. In the case of an
application without reference to an advertised position (unsolicited application), theapplication will be kept for a maximum period of one (1) year in order to contact you, if
necessary, with regard to a vacancy that arises during this time. You have the option ofrequesting the deletion of your application at any time prior to expiry of the scheduled
retention periods. In the case of a successful application, the data provided to us will be
stored in your employee file in compliance with the legal requirements.

13.3.

If you have applied for a position with a related company that is part of the FinPros Group,
we will forward your application to the respective company for the purpose of deciding
on the establishment of an employment relationship.

13.4.

As far as we process your data for the decision on the establishment of an employment
relationship, the legal basis the performance of our employment contract with you andour legitimate interests of managing our relationship with you (where the processing
activities are not strictly speaking necessary for the performance of a contract.

13.5.

In all other instances, the legal basis for storing your application data is your consent inaccordance with Art. 6(1) lit. (a) GDPR.

14.

WHERE WE KEEP YOUR PERSONAL DATA

14.1.

All your Personal Data in electronic format (e-mails, documents, databases, uploaded
batches of data, etc.) are stored on specially protected servers maintained by theCompany or its contractors, which are located either in the United Kingdom and/or in theEuropean Union. All processing operations are carried out pursuant to the European
General Data Protection Regulation (the “GDPR”) (EU) 2016/679.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 27 of 35

Privacy Policy
14.2.

All our contractors are bound by specific contractual clauses for any processing
operations of your data on our behalf, and by the confidentiality obligations deriving fromthe GDPR.

14.3.

To protect your Personal Data, we have put in place a number of technical andorganizational measures. Technical measures include appropriate actions to address
online security, risk of data loss, alteration of data or unauthorized access, taking into
consideration the risk presented by the processing and the nature of the Personal Databeing processed.

14.4.

Your Personal Data is encrypted and transmitted over the Internet. We use SSL encryption(Secure Socket Layer) for data transmission.

14.5.

Organizational measures include restricting access to the Personal Data solely toauthorized persons with a legitimate need to know for the purposes of this processing
operation.

15.

DISCLOSURES OF YOUR PERSONAL DATA

15.1.

We may have to share your Personal Data with third parties for the purpose of carryingout our services, but should this be the case, we will check whether this is required or
permitted by applicable laws, rules and/or regulations, and will put in place specificcontractual clauses for any processing operations of your data on our behalf, and by theconfidentiality obligations deriving from the GDPR.

15.2.

We require all third parties to respect the security of your Personal Data and to treat it inaccordance with applicable laws, rules and/or regulations. We do not allow our thirdparty service providers to use your Personal Data for their own purposes and only permit
them to process your Personal Data for specified purposes and in accordance with our
instructions and applicable laws, rules and/or regulations.

15.3.

We may also share your information, including your Personal Data, with our affiliates andother third parties, such as companies with whom we have marketing or otherrelationships, for direct marketing purposes (“Related Parties”) In addition, we may sharethe information we have collected about you, including Personal Data, as disclosed at thetime you provide your information and as described in this Privacy Policy.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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15.4.

Examples of when Related Parties may share your information, include the following:

A. Other Community Members
15.5.

Certain features of our Site(s) and Services may allow you to share comments publicly
with other users. Any information that you submit through such features is not confidential
and can be used by us for any purpose. In addition, when you use our Site or the Services,
we may share certain Personal Data (such as your name, photo, contact information, orother information you have made visible in the App or Site) to other users of the App or
Site in order to facilitate contact among residents and/or between residents and our
representatives.

15.6.

Note that other users are not bound by our Privacy Policy. You agree that we are notresponsible for the actions of other users with respect to any Personal Data disclosed in
the App or Site. It is important that you review the applicable Privacy Policy for the event,sponsoring organization, property or Location before providing your information inconnection with that event. We request that you treat all Personal Data received aboutother Users with the same respect and care you would want for your own information.

B. Third Parties Providing Services to us
15.7.

We may use Third-Party Service providers to perform certain services on behalf of us or
the Site(s) or Services, such as: (i) creating and updating Site(s) and app functionality; (ii)billing or processing credit cards, and/or electronic or manual payments; (iii) assisting us
in Site(s) and app operations; (iv) managing a database of customer and consumer
information; (v) hosting the Site(s); (vi) designing and/or operating the Site’s features;(vii) tracking the Site’s activities and analytics, including marketing and market research;(viii) data enhancement (to learn more about our customers); (ix) enabling us to send
you special offers or perform other administrative services, such as customer service,
security, tech, operational support, email and legal services; and (x) other services
designed to assist us in maximizing our business potential. We may provide these ThirdParty Service pro with access to user information to carry out the services they are
performing for you or for us. Those vendors may have additional or different privacy
policies and/or Terms of Service. You should be sure that you read and agree to thosepolicies and Terms.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Privacy Policy
C. To Protect the Rights of Related and Others
15.8.

To the fullest extent permitted by applicable law, we may also disclose your information
when required to by law or if we believe in good faith that doing so is necessary or
appropriate to: (i) protect or defend our own rights, safety or property and the rights,
safety or property of Related Parties, their affiliates, third parties or the general public(including through the enforcement of this Privacy Policy, our Website terms of Accessand Use, and any other applicable agreements and policies); (ii) comply with legal andregulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court
orders); or (iii) to respond to claims that any content violates the rights of a third party.
This includes exchanging information with other companies and organizations for fraud
prevention, spam/malware protection, and other similar purposes. To the fullest extent
permitted by applicable law, we have complete discretion in electing to make or not makesuch disclosures, and to contest or not contest any requests for such disclosures, allwithout notice to you.

D. Affiliates and Business Transfer
15.9.

We may share your information with our parent company(ies), subsidiaries, and affiliates.
As part of this sharing of information with our parent company(ies), subsidiaries andaffiliates, this means that once you provide us with information, any one of our related
entities may use your information including for marketing purposes, pursuant to the termsof this Privacy Policy. We also reserve the right to disclose and transfer all such information:(i) to a subsequent owner, co-owner or operator of the Site and/or our Services; or (ii) inconnection with a merger, consolidation, restructuring, the sale of substantially all of ourinterests and/or assets or other corporate change, including during any due diligenceprocess.

16.

CHANGE OF PURPOSE

16.1

We will only use your Personal Data for the purposes for which we collected them, unless
we reasonably consider that we need to use it for another reason and that reason iscompatible with the original purpose. If you wish to get an explanation as to how theprocessing for the new purpose is compatible with the original purpose, please contact
us. If we need to use your Personal Data for an unrelated purpose, we will notify you andwe will explain the legal basis, which allows us to do so.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Privacy Policy
16.2

Please note that we may process your Personal Data without your knowledge or consent,in compliance with the above rules, where this is required or permitted by applicable laws,
rules and/or regulations.

17.

INTERNATIONAL TRANSFERS OF PERSONAL DATA

17.1.

We might need on certain occasions for the purposes of carrying out our services totransfer your Personal Data outside the European Economic Area (EEA).

17.2.

Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree ofprotection is afforded to it by ensuring at least one of the following safeguards is
implemented:•

We will only transfer your Personal Data to countries that have been deemed toprovide an adequate level of protection for Personal Data by the European
Commission.

•

Where we use certain service providers, we may use specific contracts approvedby the European Commission, which give Personal Data the same protection it has
in Europe.

•

Where we use providers based in the US, we may transfer data to them if they arepart of the Privacy Shield, which requires them to provide similar protection to
Personal Data shared between the Europe and the US.

17.3.

Please contact us if you want further information on the specific mechanism used by us
when transferring your Personal Data out of the EEA.

18.

DATA SECURITY

18.1.

We have put in place appropriate security measures to prevent your Personal Data frombeing accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In
addition, we limit access to your Personal Data to those employees, agents, contractors
and other third parties who have a business need to know. They will only process your
Personal Data on our instructions and they are subject to a duty of confidentiality.

18.2.

We have put in place procedures to deal with any suspected Personal Data breach andwill notify you and any applicable regulator of a breach where we are legally required to
do so.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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19.

DATA RETENTIONA.

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

19.1.

We will only retain your Personal Data for as long as necessary to fulfil the purposes wecollected it for, including for the purposes of satisfying any legal, accounting, or reporting
requirements.

19.2.

To determine the appropriate retention period for Personal Data, we consider the amount,nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized
use or disclosure of your Personal Data, the purposes for which we process your Personal
Data and whether we can achieve those purposes through other means, and theapplicable legal requirements.

19.3.

By law, we have to keep basic information about our customers (including Contact,
Identity, Financial and Transaction Data) for five years after they cease being customers
for regulatory purposes.

B.

ERASURE OF YOUR PERSONAL DATA

19.4.

In some circumstances, you can ask us to delete your data: see Request erasure below
for further information.

19.5.

In some circumstances we may anonymize your Personal Data (so that it can no longer
be associated with you) for research or statistical purposes in which case we may use thisinformation indefinitely without further notice to you.

20.

YOUR LEGAL RIGHTSA.

THE VARIOUS RIGHTS YOU HAVE

20.1.

Under certain circumstances, you have rights under data protection laws in relation to
your Personal Data:➢ Request access to your Personal Data (commonly known as a “data subject accessrequest”). This enables you to receive a copy of the Personal Data we hold about you
and to check that we are lawfully processing it.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 32 of 35

Privacy Policy➢ Request correction of the Personal Data that we hold about you. This enables you tohave any incomplete or inaccurate data we hold about you corrected, though we mayneed to verify the accuracy of the new data you provide to us.
➢ Request erasure of your Personal Data. This enables you to ask us to delete or remove
Personal Data where there is no good reason for us continuing to process it. You also
have the right to ask us to delete or remove your Personal Data where you havesuccessfully exercised your right to object to processing (see below), where we may
have processed your information unlawfully or where we are required to erase your
Personal Data to comply with local law. Note, however, that we may not always be able
to comply with your request of erasure for specific legal reasons, which will be notified
to you, if applicable, at the time of your request.
➢ Object to processing of your Personal Data where we are relying on a legitimate
interest (or those of a third party) and there is something about your particularsituation, which makes you want to object to processing on this ground as you feel it
affects your fundamental rights and freedoms. You also have the right to object where
we are processing your Personal Data for direct marketing purposes. In some cases,
we may demonstrate that we have compelling legitimate grounds to process yourinformation, which override your rights and freedoms.
➢ Request restriction of processing of your Personal Data. This enables you to ask us tosuspend the processing of your Personal Data in the following scenarios: (a) if you want
us to establish the data’s accuracy; (b) where our use of the data is unlawful but you
do not want us to erase it; (c) where you need us to hold the data even if we no longer
require it as you need it to establish, exercise or defend legal claims; or (d) you have
objected to our use of your data but we need to verify whether we have overriding
legitimate grounds to use it.
➢ Request the transfer of your Personal Data to you or to a third party. We will provide toyou, or a third party you have chosen, your Personal Data in a structured, commonly
used, machine-readable format. Note that this right only applies to automatedinformation which you initially provided consent for us to use or where we used theinformation to perform a contract with you.
➢ Withdraw consent at any time where we are relying on consent to process your
Personal Data. However, this will not affect the lawfulness of any processing carried out
before you withdraw your consent. If you withdraw your consent, we may not be able

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 33 of 35

Privacy Policy
to provide certain products or services to you. We will advise you if this is the case at
the time you withdraw your consent.
20.2.

Any questions about this ‘Privacy Policy’ can be directed to our Compliance Department:compliance@finpros.com.

20.3. Also, if you wish to exercise any of the rights set out above, please contact our ComplianceDepartment: compliance@finpros.com.

B.

NO FEE USUALLY REQUIRED

20.4. You will not have to pay a fee to access your Personal Data (or to exercise any of the otherrights). However, we may charge a reasonable fee if your request is clearly unfounded,
repetitive or excessive. Alternatively, we may refuse to comply with your request inthese circumstances.
C.

WHAT WE MAY NEED FROM YOU

20.5. We may need to request specific information from you to help us confirm your identityand ensure your right to access your Personal Data (or to exercise any of your otherrights).
20.6. This is a security measure to ensure that Personal Data is not disclosed to any person who
has no right to receive it. We may also contact you to ask you for further information in
relation to your request to speed up our response.

D.

TIME LIMIT TO RESPOND

20.7.

We try to respond to all legitimate requests within one (1) month.

20.8. Occasionally it may take us longer than a month if your request is particularly complex or
you have made a number of requests. In this case, we will notify you and keep you
updated.

21.

RIGHT TO COMPLAIN

21.1.

You have the right to complain about the handling of your personal data to a dataprotection authority.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Privacy Policy
22.

RIGHT OF OBJECTION

22.1.

If your personal data are processed on the basis of legitimate interests pursuant to Art.
6(1)(f) GDPR, you have the right to object to the processing of your personal data inaccordance with Art. 21 GDPR, provided there are reasons for this arising from yourparticular situation or if your objection is based on being targeted to marketing purposes.
In the latter case, you have a general right of objection, which is implemented by us
without any particular situation being specified.

23.

REVIEWING THIS POLICY

23.1.

We encourage our Clients to review this Privacy Policy periodically, so that you are always
aware of what information we collect, how it is used and to whom it may be disclosed.
___________________‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 35 of 35