Privacy Policy
Effective date: October 2023

PRIVACY POLICY
1.

INTRODUCTION

This Privacy Policy applies to all entities within the LMAX Group (“we”, “us”, “our”, “ours”,“ourselves” or “LMAX Group” as appropriate), and sets out the basis on which we collect, process
and use your personal data when one or more of our entities deal with you, including when you access ourWebsite (www.lmax.com) and use our Trading Platform.
We are committed to protecting your privacy and personal information. Please read this Privacy Policy
carefully to ensure you understand our views and practices regarding your personal data and how wewill treat it. If you have any questions you can contact us using the details below. Please alsorefer toour Cookie Policy [https://www.lmax.com/documents/LMAXGroup-Cookie-Policy.pdf] which sets out
the use of cookies and other web tracking technology via our website.

2.

INFORMATION WE MAY COLLECT

We may collect the following personal information which we have grouped together as follows:•Information that you provide by filling in forms on our Website to register you as acustomer, create an account or to otherwise provide you with our products and services
such as your name, email address, home address, date of birth, copies of your identity documents(including photo ID), email address, telephone number and mobile number, financial status,statements and background, and proof of address documentation. We may automatically capture,
store or otherwise process this information about you even if you abandon the application
process. We may also collect personal information if you report a problem with the Website.
Personal data may include sensitive data, for example information about an individual consistingof racial or ethnic origin.

•Account information such as your username, password, account number, account balance,trading activity and history, interests and preferences, and commission charged.

•Financial information such as your bank account and payment card details.

•Use of our services information such as information about your use of our Website, products
and services. This includes your preferences, feedback and survey responses as well as trading
activity, history and commission charged•Telephone recordings if you contact us by telephone we may monitor and/or record yourconversations with us and retain the recordings for such periods as may be necessary or required bylaw.

•Technical information such as your internet protocol (IP) address, login information, browser
type and version, time zone setting, operating system and platform, server logs and other similardata.

LMAX Group is the holding company of LMAX Exchange, LMAX Global and LMAX Digital. Our registered address isYellow Building, 1A Nicholas Road,
2•Marketing and communications information such as your preferences in receiving marketingfrom us and our third parties, and records of correspondence you have entered into with us via email, live chat, post or telephone.

We may also collect aggregated or de-identified data when you use our Website or Trading Platform.
For example, we may use Uniform Resource Locators (URL) clickstream analysis information tocollect, analyse and report data about which site you have visited our Website from and which site
you go to after our Website, which pages you visit and in what order, length of visits to certain pages,
page response times, page interaction information, products you have viewed or searched for,download errors and methods used to browse away from the page.

3.

HOW WE USE YOUR PERSONAL INFORMATION

We collect, use, disclose, transfer and store personal data when needed to provide you with ourservices and for our operational, legal, regulatory and business purposes in relation to those services
and as described in this policy. We may use your personal information for the following purposes:•To create an account for you and register you as a customer and to set up and administeran account for you, including to provide you with any technical or customer support [or to provide
you with training].

•

To verify your identity and conduct checks on our customers including initial and ongoinganti-money laundering, sanctions, fraud, credit risk and customer due diligence checks which weare required to complete (which may be done by our third party service providers). We may use
and retain this information even after you have closed your account.

•

To provide you with information, products or services you request and to respond to yourquestions.

•To make suggestions about new products and services that may be of interest to you•

To administer our Website and Trading Platform including troubleshooting, data analysis,testing, system maintenance and support, reporting and hosting of data.

•To personalize your experience as a customer on our Website and Trading Platform.

•

To protect the security of our Website and Trading Platform including through preventing
and detecting security breaches, fraud or other criminal or malicious activities.

•

To notify you about changes to our products or services including any changes to our Termsof Business, Cookies Policy, or Privacy Policy.

•To analyse and make improvements to our products or services through data analytics,research and auditing.

•To enable you to participate in surveys, competitions, draws that may be of interest to you
where you have been consented to be contacted for such purposes.

•To comply with any other applicable law or regulation including any court order or any legal
or regulatory requirements.

We aim to provide you with choices in relation to certain personal data uses, such as marketing andLMAX Group is the holding company of LMAX Exchange, LMAX Global and LMAX Digital. Our registered address isYellow Building, 1A Nicholas Road,3advertising communications. If you receive any communications from us and you want these to stop
you can unsubscribe to our marketing communications. If you unsubscribe to marketing
communications, you will still continue to receive operational communications from us that we deem
necessary for the operation of your account.

We do not disclose information about identifiable individuals to our third-party advertisers or partners
who provide content to our Website, but we may provide them with aggregate information about ourusers and we may also use such aggregate information to help advertisers to reach the kind ofaudience they want to by placing their advertisements on our Website.

4.

WHY WE PROCESS YOUR INFORMATION

We may be required to retain, process and use your personal information on one or more legal
grounds: (i) the processing is necessary for the performance of the agreement between you and us;(ii) to comply with our legal or regulatory obligations or; (iii) the processing is necessary for ourlegitimate interests or the legitimate interests of a third party that receives your personal data,
provided that such interests are not overridden by your interests or fundamental rights and freedom.
In addition, the processing may be based on your consent where you have expressly given that to us.

5.

WHEN WE SHARE OR DISCLOSE YOUR INFORMATION

We may share or disclose your personal information with the following parties. When we sharepersonal data, we do so in accordance with applicable data privacy laws and our internal security
standards.

•The LMAX Group: We may make personal information available to any member of our group,
which means any subsidiary company or holding company, and/or any subsidiary company ofsuch holding company (the Group). This may be necessary to provide you with or administerour products, services, customer and technical support. All of our employees and contractors
are required to follow our privacy and security policies when handling personal data.

•Third party service providers: We may share your personal information with our third party
service providers so that they can support our products and services, such as system andplatform maintenance services, conducting customer due diligence or credit checks, collecting
customer feedback, marketing and advertising services, and data analytics and search engine
services. Our third-party service providers are permitted to use your personal information only
for the purpose of providing services to us and may not otherwise share or use your personalinformation.

•Fraud prevention and credit reference agencies: We may share your personal information with ourthird-party service providers to conduct anti-money laundering, fraud, sanctions, credit risk andcustomer due diligence checks, credit reference checks and fraud prevention checks.

•Introducers and advisers: We may disclose your personal information to an introducer if they
directed you to us.

LMAX Group is the holding company of LMAX Exchange, LMAX Global and LMAX Digital. Our registered address is
Yellow Building, 1A Nicholas Road,
4•

Courts, regulators and law enforcement agencies: We will share your personal information
when we believe it is required to comply with applicable legal or regulatory obligations and torespond to requests from government authorities, including law enforcement or financial
regulators. This may include authorities outside your country of residence.

•

Other third parties: We may share personal information in the event of a merger, sale,
restructure, acquisition, joint venture, assignment, transfer or other disposition of all or any
portion of our business, assets or stock (including in connection with any bankruptcy or similar
proceedings). We may also make personal information available to protect our rights, users,systems and services.

6.

WHERE WE TRANSFER AND STORE YOUR PERSONAL INFORMATION

European Customers based in the EEA
The personal information that we collect from you may be sent, stored at, and used in a country
outside the European Economic Area (EEA consisting of EU, Norway, Iceland & Liechtenstein) which may
not offer the same level of protection as the EEA. It may also be processed by staff operating outside
the EEA who work for us, one of our suppliers, introducers, business partners, agents or subcontractors. By submitting your personal data, you agree to this transfer, storing and processing.

Customers from the rest of the WorldThe data that we collect from you may be stored in a jurisdiction that is different to the country inwhich the specific LMAX entity you are dealing with is registered and established. It may also betransferred outside of the country in which the specific LMAX entity you are dealing with is registeredand established, and processed by staff operating in another country but who are neverthelessemployed by us, one of our suppliers, Introducers, business partners, agents or sub-contractors. By
submitting your personal data, you agree to this transfer, storing and processing.
In both cases above, we will take all steps reasonably necessary to ensure that your personal
information is treated securely and in accordance with our legal obligations and standards. Where
this is not possible and we are required to disclose your personal information, for example because
we are required by law to disclose your personal information, we will do this in accordance withapplicable legal and regulatory obligations. You may contact us anytime using the contact details
below if you would like further information on such safeguards.

7.

INFORMATION SECURITY

We will implement and maintain the appropriate technical and organizational measures to keep yourpersonal information secure and to protect it from damage, loss, alteration, unauthorized access ordisclosure, unlawful or accidental destruction. For example, we will use the following types ofmeasures, where appropriate: (i) encryption of personal information, (ii) back-up servers andfacilities, (iii) testing, and (iv) ongoing monitoring of the effectiveness of security measures.
We have put in place procedures to deal with any suspected personal data breach and will notify you
and any applicable regulator of a breach where we are legally required to do so.

LMAX Group is the holding company of LMAX Exchange, LMAX Global and LMAX Digital. Our registered address isYellow Building, 1A Nicholas Road,5

8.

INFORMATION RETENTIONWe will only retain your personal information for as long as required to fulfil the purposes for which
we collected it, including any legal, regulatory, business or reporting requirements. When deciding
the length of the retention period we take into consideration applicable law, regulation, our agreement withyou, and the expectations and requirements of our customers.

9.

YOUR RIGHT OF ACCESS TO YOUR PERSONAL INFORMATION

Subject to certain legal conditions, you have certain rights in relation to your personal information.
Generally speaking, all customers of the LMAX Group have the right to ask us not to process yourpersonal data for marketing purposes. We will usually inform you before collecting your data if we intend
to use your data for such purposes or if we intend to disclose your information to any third party for such
purposes. You can exercise your right to prevent such processing by checking certain boxes on theforms we use to collect your data. You can also exercise the right at any time by contacting us using
the contact details in section 11 of this Policy.

European Customers
Additionally, if you are a European Customer as described in this Policy, you are legally entitled tocertain additional rights including:• Access to personal information: You have the right to ask us for copies of the personal
information we hold on you and information regarding our processing activities. Before providing
you with access, we may ask you to provide evidence of your identity and we may be unable todisclose some of the information for legal or regulatory reasons. You can request us to provide theinformation to you by using the Subject Access Request Form:(https://www.lmax.com/documents/LMAXGroup-Subject-Access-Request-Form.pdf).

• Right to rectification: You have the right to ask us to correct or amend your personal information
if it is inaccurate, requires updating, or is incomplete.

• Right to erasure: You also have the right to request us to delete your personal information unless weare required to hold it for legal or regulatory reasons or our own internal compliance requirements.

• Right to object to or restrict processing of your personal information: You have the right torequest us to stop all processing altogether or for a certain purpose.
In circumstances where you ask us to erase or stop processing your personal data, this may result in
us being unable to continue to provide you with our services and/or closing your account with us.
If you wish to exercise any of these rights, please contact us using the details found in section 11.
We will respond to any requests referenced above within twenty-eight (28) days of receipt. If
we require more information from you, or if your request is unusually complicated, we may require
more time and will inform you accordingly.
We will not usually charge you a fee for a request. However, we may charge a reasonable fee if yourrequest is clearly unfounded, repetitive or excessive.

LMAX Group is the holding company of LMAX Exchange, LMAX Global and LMAX Digital. Our registered address isYellow Building, 1A Nicholas Road,
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You may also make a complaint if you have a concern about our handling of your personalinformation. We will consider any complaints which we receive and provide you with a response ina timely manner. If you are not satisfied with our response, you may take your complaint to therelevant privacy regulator. We will provide you with details of your relevant regulator upon request.

10.

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our Privacy Policy in the future will be posted on our Website. This policy
was last updated on 1 November 2019. Please check our Website frequently to see any updates orchanges to our Privacy Policy. If we make changes which are significant we will provide a prominent
notice or notify you through other means

11.

CONTACT US

Questions, comments and requests regarding this Privacy Policy are welcomed and should be
addressed to:Company nameAddress

LMAX Broker Europe Limited
Office 101
10 Evagoras Papachristoforou Street3030 Limassol, Cyprus

Contact
T: +35725 022 214
E: info@lmax.com

LMAX Broker Limited

Yellow Building 1A
Nicholas RoadLondon
W11 4AN
United Kingdom

T: +44 20 3192 2555
E: info@lmax.com

LMAX Broker Mauritius Limited

C/p GFin Corporate Services Ltd,
Level 6, GFin Tower, 42 Hotel Street,
Cybercity, Ebene 72201, Mauritius

T: +230 404 3900
E: info@LMAXMauritius.com

LMAX New Zealand Limited

LMAX c/o Quigg
Partners, Level 7, 36
Brandon Street,Wellington, 6011, NewZealand

T: +64 4889 4510
E: info@lmax.com

LMAX Digital Broker Limited

Office 234 Regus
World Trade Center
Bayside Road
Gibraltar

T: +44 33 3700 4096
E: info@LMAXdigital.com

LMAX Group is the holding company of LMAX Exchange, LMAX Global and LMAX Digital. Our registered address is
Yellow Building, 1A Nicholas Road,
7

LMAX Digital Broker (PTE)
Limited

9 Raffles Place#17 – 20/21 Republic
Plaza
Singapore
048619

T: +65 6958 0556
E: info@LMAXdigital.com

LMAX Limited

Yellow Building 1A
Nicholas RoadLondon
W11 4AN

T: +44 20 3192 2563

United Kingdom
LMAX PTE Limited

9 Raffles Place#17 – 20/21 Republic
Plaza
Singapore
048619E:
institutionalsales@LMAX.com

T: +65 6958 0556
E:
institutionalsales@LMAX.com

Our Client Services team is available for 24-hour support, Sunday 22.00 – Friday 22.00 UK time.
Telephone calls will be recorded and/or monitored.

LMAX Group is the holding company of LMAX Exchange, LMAX Global and LMAX Digital. Our registered address isYellow Building, 1A Nicholas Road,
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