Privacy Policy

Mitsui Markets Ltd.
113 Santina Parade, Elluk, Port Vila,Efale, Vanuatu

Privacy Policy

TABLE OF CONTENT
1.

INTRODUCTION ......................................................................................................................... 2

2.

WHO WE ARE ............................................................................................................................ 2

3.

PERSONAL DATA ..................................................................................................................... 2

4.

3.1.

Information We Collect ................................................................................................. 2

3.2.

KYC ................................................................................................................................ 3

3.3.

How We Acquire Your Data ......................................................................................... 4

3.4.

Purposes .......................................................................................................................... 4

DISCLOSURE OF INFORMATION ............................................................................................ 4

4.1.

To Whom We Disclose Information ........................................................................... 44.2.

Third-Party Sites............................................................................................................. 64.3.

Payment Providers ........................................................................................................ 64.4.

International Transfers ................................................................................................. 65.

CONSENT ................................................................................................................................... 6

6.

YOUR LEGAL RIGHTS .............................................................................................................. 77.

SECURITY .................................................................................................................................. 8

8.

7.1.

Retention of Records .................................................................................................... 87.2.

Security Measures ......................................................................................................... 8

GENERAL ................................................................................................................................... 8

8.1.

Changes to the Privacy Policy.................................................................................... 88.2.

Compliance with Applicable Legislation ................................................................. 98.3.

Questions, Problems, or Complaints ........................................................................ 91
Mitsui Markets Ltd.

Address: 113 Santina Parade, Elluk, Port Vila, Efale,Vanuatu

Privacy Policy

Last Revised: February 2023

1. INTRODUCTION
Mitsui Markets Ltd (hereinafter the “Company”, “we”, “our”, or “us”) is a Vanuatu-based securities
firm registered under registration number 14812.
The Company’s Business office is at 133 Santina Parade, Elluk, Port Vila, Efate, Vanuatu.
The protection of the security and privacy of your Personal Data is important to us and to the way weconduct our business in compliance with the laws on privacy, data protection, and data security.
This Privacy Policy, together with our Terms and Conditions applicable to you and any additional
provisions that may be incorporated by reference into the terms apply to your use of our services, oursite accessible from jpfbs.com (“Website”), and any of the services accessible through the Website
and our products (collectively referred to as “Service”).
The purpose of this Privacy Policy is to outline what information the Company may collect, how it uses
and safeguards that information, and with whom we may share it.

2. WHO WE ARE
Mitsui Markets Ltd. is the data controller and is responsible for your Personal Data.
Our full details are as follows:••

Postal address: 133 Santina Parade, Elluk, Port Vila, Efate, Vanuatu
Email address: office@mitsuimarkets.com

3. PERSONAL DATA
3.1. Information We Collect1.

We will collect the following personally identifiable information (“Personal Data”):

Personal details

Full name, e-mail address, gender, home address, phone address, phone
number, date of birth, nationality, signature, utility bills, photographs, and avideo recording of the Client

Contact Information

E-mail address, country, region

Sensitive and Biometric
Personal Data

Sensitive personal data, when permitted by local law or with Client consent,such as biometric information, for example, to verify the Client’s identity bycomparing the facial scan data extracted from Client’s selfie or video withthe photo in Client’s government issued identity document

Government Identifiers

Government issued identity documents such as passport, national
identification number, national identity card details, driver’s license numbers

Financial details

Assets, liabilities, income, expenses, bank account information, payment
card information, source of funding, source of wealth, job title, salary wagerate

Taxation information

tax file number2
Mitsui Markets Ltd.

Address: 113 Santina Parade, Elluk, Port Vila, Efale,
VanuatuPrivacy Policy

Broad location data

country location

Browsing Information

IP address, geolocation, browser type/version, and operating system

Data about device

manufacturer, operating system, CPU, RAM, browser type and language,
current time

Usage data

data we collect with cookies and similar technologies

Marketing and ResearchInformation

Data for advertising and analytics purposes so we can provide the Client with
better service (e.g. browser/web history data and preferences expressed
through selection/viewing/purchase of goods, services and content,
information about Client’s mobile device including (where available) type ofdevice, device identification number, mobile operating system.)Trading experience

Information relating to the previous trading experience, personal goals, andobjectives

Other data the Client choose to give the Company.
2. Account/Personal Area passwords are stored in the system and are not public information for
employees of the Company who do not need it for the purpose of providing services to the Client.
3.

Through its Website (s), the Company will not collect any Personal Data unless you voluntarilychoose to provide it (e.g., by registration, email inquiry, survey, etc.). If you do not want your
Personal Data to be collected, please do not submit it.

4.

We will process your Personal Data legally and fairly and will not use it outside the purposes ofwhich we have informed you, including selling it individually or in the aggregate for commercialuse.

5.

We retain Personal Data in an identifiable format for the least amount of time necessary to fulfill
our legal or regulatory obligations and for our business purposes. We may retain Personal Datafor longer periods than required by law if it is in our legitimate business interests and is not directly
prohibited by the applicable law. If your account is deleted, we may take steps to mask Personal
Data and other Data, but we reserve our right to retain and access the data for as long as required
to comply with applicable laws. We will continue to use and disclose such Personal Data inaccordance with this Policy.

6.

We also collect, use, and share aggregated data, such as statistical or demographic data, for any
purpose (“Aggregated Data”). Aggregated Data could be derived from your Personal Data but
is not considered Personal Data by the law as this data will not directly or indirectly reveal youridentity. For example, we may aggregate your usage data to calculate the percentage of users
accessing a specific software feature. However, if we combine or connect Aggregated Data withyour Personal Data so that it can directly or indirectly identify you, we treat the combined data as
Personal Data which will be used in accordance with this Privacy Policy.

3.2. KYC
During the Know Your Client (KYC) process, we are also required by law to collect certain
documentation in order to verify your true identity, which may include, but is not limited to, proofof identity in the form of Identity documents, proof of your permanent residential address in theform of a utility bill, as well as your credit card details (we request both sides of the bank card.
The front side must contain the first 6 digits and the last 4 digits of the card number, thecardholder’s name, and expiry date, signature. For security purposes, we request clients cover
3Mitsui Markets Ltd.

Address: 113 Santina Parade, Elluk, Port Vila, Efale,
VanuatuPrivacy Policy

the CVC/CVV codes on the back side). User’s card data is not stored in our systems since we
do not have a PCI DSS certificate. For all that information, we rely on our Payment Providers,
who are duly certified.

3.3. How We Acquire Your Data
Information may come from the following sources:

1.

••
•
•

directly from you (from our communication and/or forms that you filled in)cookies stored in your browser by our Website
IP-address
other sources, including third parties and publicly available sources

We may combine that with information we collect via our services.

2.

3.4. Purposes
We collect Personal Data for the following purposes:
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.

13.
14.
15.
16.
17.

to authenticate your access to an account;to manage your account and keep you updated on all matters that concern your account;to provide the services that you have requested, including processing transactions;
to respond to your requests, for example, to contact you about a question you submitted to ourcustomer service team;to provide the functionality of our products;
to inform you about changes in our services, our service offering, and other important servicerelated notices;to protect our rights and interests, as well as the rights and interests of our users and any otherperson;
to carry out any actions for which we have received your consent;
to perform research and analysis about your use of, or interest in, our products, services, orcontent, or products, services, or content offered by others;
to comply with applicable legal or regulatory obligations, including complying with requests fromlaw enforcement or other governmental authorities or in legal proceedings;
to fulfill our contractual obligations;
to communicate with you, either directly or through one of our partners, including for customer
service, to provide you with updates and other information relating to the Website, and formarketing and promotional purposes;
to tailor the Website or other service we provide to you relating to your needs and interests;
to create anonymous statistical data;
to prevent and investigate fraudulent or other criminal activity;
to congratulate you;to offer you personalized and/or unique offers, services, products.

4. DISCLOSURE OF INFORMATION
4.1. To Whom We Disclose Information
1.

Your Personal Data may be disclosed to different recipients. The list below provides some of thetypes of recipients and reasons for sharing your Personal Data.
Category of recipient

Our affiliates

Examples orexplanation
Any legal entity
affiliated with theCompany

Share purpose•••

Providing the basic services under
the Terms and Conditions;
Organizing the work of customer
support service;
Any other purpose deemednecessary by the Company.
4Mitsui Markets Ltd.

Address: 113 Santina Parade, Elluk, Port Vila, Efale,
VanuatuPrivacy Policy

Financial institutions andother similarorganizations

Any suchorganizations that
the Company deals
with in the courseof its business•

Partner (IntroducingBroker Program
participant)Those who had
been contracted toprovide us withadministrative,
financial,insurance,research, and/or
other services.

•Auditors, lawyers, andother examination
organizations

Any entity
conducting an audit
or otherlegal/financial
check

Third-party service
providers whoseactivities are required toperform the service

Web hosting,information
technology
providers

Payment partners

Data aggregation,
analytics, and market
research services•

Providing the basic services under
the Company’s legal agreements;• Notifying the Partner that someone
has registered using their Partner
IDs or other identification tools or
has unsubscribed from the Partner.
In this case, we can give your nameand contact information to thePartner;• Communicating with you throughone of our Partners, including forcustomer service, to provide youwith updates and other information
relating to the Website and formarketing and promotional
purposes.
Complying with our legal obligations
imposed by applicable laws (in certain cases
provided by law).

Providing the basic services under theTerms and Conditions.

Enabling purchase opportunities within ourservices. These payment processors areresponsible for the processing of your
Personal Data and may use your Personal
Data for their own purposes in accordancewith their Privacy Policies.
Google Analytics,Google Ads••••Advertising partners

Any partners••

Relevant parties in theevent of a change incontrol, merger, oracquisition
Authorities and parties
where relevant forcompliance with various
laws

Providing the basic services under
the Terms and Conditions;
Complying with our legal obligations
imposed by applicable laws (incertain cases provided by law).

Creating and utilizing analytics on
our services and audience;
Conducting advertising andmarketing activity;
Conducting surveys and research;
Personalizing our services for you.
Conducting advertising andmarketing activity;
Personalizing our services for you.

As our business develops, we may sell orbuy businesses or assets. In the event of acorporate sale, merger, reorganization,dissolution, or similar event, Personal Data
may be part of the transferred assets.
Any authority

Compliance with our legal obligations
imposed by applicable laws.

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Mitsui Markets Ltd.

Address: 113 Santina Parade, Elluk, Port Vila, Efale,
VanuatuPrivacy Policy

2.

Please note that we will never sell the Client’s Personal Data.

3.

In general, we require that any third-party service provider that we share any Personal Data withundertakes to respect any individual’s right to privacy and comply with the Data Protection
Principles. These third-party service providers may keep a record of any searches they performedon our behalf, and they may use the search details to assist other companies in performing theirsearches. This Privacy Policy does not cover the practices of third parties.

4.

In cases where the Client is attached to a Partner, such Partner may have access to the Client’sinformation. Hence, the Client hereby consents to share information with such Partner. We
provide Partners only the minimum necessary data required for the purpose of the Partner
Agreement.

4.2. Third-Party Sites
Please be notified that Mitsui Markets Ltd. cannot be held responsible for the privacy practicesof other websites. We advise all visitors to be aware and read the privacy statements of every
Website that collects personal identity information.

4.3. Payment Providers
In accordance with the recommendations of the Payment Card Industry Security Standards
Council, customer card details are protected using Transport Layer encryption – TLS 1.2 andapplication layer with algorithm AES and key length 256 bit.

4.4. International Transfers
1.

We operate all over the world, and therefore we may transfer your data to our counterparties(partners, affiliates, etc.) in different countries, including those which are located outside thecountry in which you are based. We take all necessary steps, including those imposed on us by
applicable law, to ensure an adequate level of Personal Data protection in each case. However,
we would like you to consider that the countries to which we transfer your data may not have thesame data protection laws as your jurisdiction.

2.

To facilitate our global operations, the Company may transfer, store, and process your operations
with our partners and service providers based outside of the country in which you are based.
Laws in those countries may differ from the laws applicable to your country of residence. Where
we transfer, store, and process your Personal Data outside of the country where you are based,
we will ensure that the appropriate safeguards are in place to ensure an adequate level ofprotection. Further details regarding the relevant safeguards can be obtained from us uponrequest.

5. CONSENT
1.

BY SUBMITTING INFORMATION, INCLUDING PERSONAL DATA, YOU ARE EXPRESSLYAND VOLUNTARILY ACCEPTING THE TERMS AND CONDITIONS OF THIS PRIVACYPOLICY. YOU HAVE THE RIGHT TO WITHDRAW YOUR CONSENT AND USE OF YOURINFORMATION BY CHANGING YOUR ACCOUNT SETTINGS OR CLOSING YOURACCOUNT, BUT YOUR WITHDRAWAL OF CONSENT WILL NOT BE RETROACTIVE.

2.

You should also be aware that we do not sell, rent, or disclose your Personal Data in exchange
for money or other valuable consideration to any third parties, and we shall not incorporate suchpractice in our business unless providing you with a clear and explicit way to exercise your optout right and before introducing appropriate changes to this Policy.

3.

You consent to transfer your Personal Data to third parties as described in Section 4.1. of thisPrivacy Policy, and as described in this Privacy Policy, including to carry out your instructions or
to provide our services, for the purpose of notifying a Partner of a client’s detachment unlessotherwise compelled by law or as necessary to enforce our Terms and Conditions or to protect
the rights or property of the Company or its users or the public. We may provide Aggregated Data
6
Mitsui Markets Ltd.

Address: 113 Santina Parade, Elluk, Port Vila, Efale,Vanuatu

Privacy Policy

about the usage of our Services to third parties for purposes that we deem, in our sole discretion,
to be appropriate.
4.

We will display the Personal Data you select on your profile page and elsewhere according tothe preferences you select in your account settings. This Personal Data may be made available
for public viewing to other Clients.

Marketing mailings
1.

If you provide us with your email address and agree to this Privacy Policy, our partners and wemay send you emails regarding the products we offer. You can choose to opt out of receiving
emails from us at any time. If you wish to opt out with respect to more than one email address,
you must provide a separate request for each email address. Every email sent from us will include
appropriate unsubscribe instructions. To opt out of all email marketing messages from us, you
should follow the instructions provided with each email.

2.

If you provide us with your telephone number and agree to this Privacy Policy, our partners andwe may send you texts or call you regarding the products we offer. You can choose to opt out ofreceiving texts or calls from us at any time by emailing us.

6. YOUR LEGAL RIGHTS
In accordance with applicable law, the Client may have the right to:
1. Access Personal Data about the Client.
The Client may, at any time, request access to the Client’s Personal Data, and the Company will
provide the Client with access to that information either by providing copies of the information
requested, allowing the Client to inspect the information requested, or providing the Client with anaccurate summary of the information held. The Company may, prior to providing access inaccordance with this Privacy Policy, require the Client to provide evidence of the Client’s identity.
In the event the Company refuses access to the Clients Personal Data; the Company will provide
an explanation for that refusal. The Company will endeavor to respond to any request for accesswithin 14 days depending on the complexity of the information and/or the request and may charge
fees for the request of a significant amount of information to be copied or accessed.
2. Request correction of Client’s Personal Data where it is inaccurate, incomplete, or outdated.
To assist the Company with this, please contact the Company if any details the Client has provided
change. Furthermore, if the Client believes that the information the Company has about the Client
is not accurate, complete, or up to date, please contact us, and we will take all reasonable steps tocorrect the information.
3. Request deletion, anonymization, or blocking of Client’s Personal Data.
The Client may, at any time, request the deletion of Client’s Personal Data. Please send an email:support@fbs.com to request deletion of Client’s data. We undertake to perform the deletion within
one month (30 calendar days). Please note that, under certain circumstances, the Company may
continue to process Personal Data if required to do so by applicable law.
4. Request restriction of or object to our processing of Client’s Personal Data.
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Mitsui Markets Ltd.

Address: 113 Santina Parade, Elluk, Port Vila, Efale,Vanuatu

Privacy Policy

5. Withdraw the Client’s consent to our processing of the Client’s Personal Data.
6. Request data portability and receive an electronic copy of the Personal Data that the Client hasprovided to the Company.
7. Be informed about third parties with which Client’s Personal Data has been shared.
8.

Request the review of decisions taken exclusively based on automated processing if that
could affect data subject rights.

7. SECURITY
7.1. Retention of Records
1.

We may be requested to retain and use your Personal Data to meet our legal obligations for data
security purposes and as we believe to be fit and necessary or appropriate for purposes that
include, but are not limited to,a. compliance with our requirements under applicable laws and regulations;b. responding to requests from courts and/or other public and governmental authorities;
c. monitoring through compliance and anti-money laundering processes.

2.

We will not keep your information for any longer than the time required. In many cases,
information must be kept for considerable periods of time. Retention periods will be decided,
considering the type of information that is collected and the purpose for which it is collected,
bearing in mind the requirements applicable to the situation and the need to destroy outdated,unused information at the earliest reasonable time. Under applicable regulations, we will keep
records containing Personal Data, trading information, account opening and verification
documents, communication, and anything else that is relative to the Client for a maximum ofseven (7) years after the termination of the Agreement between you and our Company. In any
event, we will keep your information for a minimum duration as provided in the applicable
Limitation of Actions Law.

7.2. Security Measures
1.

The Company takes precautions to ensure the security of your Personal Data and strives to keep
it accurate.

2.

We act with care to protect the Client’s Personal Data from loss, destruction, falsification,manipulation, and unauthorized access or unauthorized disclosure. To do so, we have developed
and will maintain security procedures to safeguard Personal Data against loss, theft, copying,
and unauthorized disclosure, use, and/or modification.

3.

Access to Personal Data is limited to the company employees and authorized service providers
who require to receive it in order to perform their work.

4.

While we will use all reasonable efforts to safeguard the Client’s information, the Client
acknowledges that the use of the Internet is not entirely secure, and therefore, we cannot
provide any guarantee concerning the security or integrity of any Personal Data transferredfrom or to the Client with the use of the Internet.

8. GENERAL
8.1. Changes to the Privacy Policy
This Privacy Policy may be modified from time to time, thus, check back often. To help you beaware if changes have been made, we will adjust the “Last Revised” date or “Date of publication”
at the beginning of this document. The new Policy may be displayed on-screen, and you may be
8Mitsui Markets Ltd.

Address: 113 Santina Parade, Elluk, Port Vila, Efale,Vanuatu

Privacy Policy

required to read it to continue using the Service, Product, or Website. Continued use of ourproducts and services by you will constitute your acceptance of any changes or revisions to thisPolicy.

8.2. Compliance with Applicable Legislation
We are committed to complying with applicable privacy and data protection laws and regulations
designed to protect your Personal Data, including the Data Protection Bill, 2021, and otherapplicable current or future regional and state privacy and data protection laws and regulations
worldwide as they become effective.

8.3. Questions, Problems, or Complaints
1.

You can contact us at office@mitsuimarkets.com if you have any questions, problems, orcomplaints regarding this Privacy Policy.

9Mitsui Markets Ltd.

Address: 113 Santina Parade, Elluk, Port Vila, Efale,Vanuatu