PRIVACY POLICY
Original Issue Date:

December 2018

Approver(s):Board of Directors

Owner(s):Contact Person:
Operational Applicability:

TTCM TRADERS CAPITAL LIMITED
Chief Executive Officer
All personnel & Clients

Last Revision Date:

December 2019

Last Reviewed Date:
Next Review Date:
Version:December 2019
December 2022
2

Other Languages:

N/A

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.
1Contents
1.

INTRODUCTION ...................................................................................................................................................................3

2.

RIGHT TO PRIVACY................................................................................................................................................................33.

INFORMATION WE COLLECT.................................................................................................................................................34.

PERSONAL INFORMATION ....................................................................................................................................................45.

ABOUT COOKIES ...................................................................................................................................................................56.

SECURITY TECHNOLOGY .......................................................................................................................................................57.

SHARING INFORMATION WITH OUR AFFILIATES ..................................................................................................................68.

SHARING INFORMATION WITH THIRD PARTIES ....................................................................................................................69.

REGULATORY DISCLOSURE ...................................................................................................................................................610. CREDIT INFORMATION .........................................................................................................................................................711.
RECORDING OF TELEPHONE CONVERSATIONS, E-MAILS, INTERNET CONVERSATIONS (CHAT), MEETINGSAND OTHER COMMUNICATIONS .................................................................................................................................................712. OPT OUT ...............................................................................................................................................................................713. CLIENT CONSENT ..................................................................................................................................................................814. MISCELLANEOUS ..................................................................................................................................................................8TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

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PRIVACY POLICY1.
1.1.

INTRODUCTION

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and6/132C(1) of the Companies Act 1981, registered with the Registrar of Companies under Company
number 54135 and with registered address 5th Floor, Andrew’s Place, 51 Church Street Hamilton HM 12Bermuda.

1.2. The Company is operating in accordance with the above mentioned Laws.

2.
2.1.

RIGHT TO PRIVACYWe respect each individual's right to privacy, we value our relationship with you, and we take pride inmaintaining loyalty and respect with each individual client by providing you with privacy and security.
The provisions of this Policy apply to former clients, as well as our current clients, and contain themanner in which we collect and maintain non-public information about our clients (such as your full
name, mailing address, identification number, passports, driver's license etc..., hencefort"Information").

2.2. We use the Information we collect from you only as appropriate to provide you with quality service andsecurity.

3.
3.1.

INFORMATION WE COLLECT

We collect Information from you when you:a. open an Account and provide us with Information through electronic registration forms;
b. make a transaction with us, including when you deposit and withdraw funds;c. additionally, from time to time, we may collect Information about you from third party entities
or agencies, such as information about your credit history.

3.2.

By providing us with Information, you are giving us your consent to collect, use and store theInformation in the manner explained hereinafter.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

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4.
4.1.

PERSONAL INFORMATION

When you apply for or maintain a live account with us, we collect personal information about you forbusiness purposes, such as evaluating your financial needs, processing your requests and transactions,informing you about products and services that may be of interest to you, and providing customer
service. Such information may include:a. Application Information: Information you provide to us on applications and other forms, suchas your name, address, birth date, social security number, occupation, assets, and income, as
well as Information required to communicate with you such as your address, phone number
and/or e-mail;b. Transaction Information: Information about your transactions with us and with our Affiliates aswell as information about our communications with you (examples include your accountbalances, trading activity, your inquiries and/or our responses);c. Verification Information: Information necessary to verify your identity such as a passport ordriver’s license (examples also include background information we receive about you frompublic records or from other entities not affiliated with us); furthermore, we may collect otheridentifiable Information such as identification numbers and/or Passport/Tax registration
numbers; we may also collect demographic information when you open an account, including
your gender, birth date, etc…; we may also need to evaluate your trading experience, averageannual income, estimated net worth and make an assessment about your risk factor.

4.2.

You directly provide us with most of the Information we collect. You do this by filling out the electronicform(s) (including, without limitation, the Account Opening Application Form(s)) that we post on ourOnline Trading Facility and by voluntarily providing us with other required documents.

4.3.

Additionally, you provide us with Information by trading on our systems, by contacting us or by
responding to a promotion; the information we indirectly collect may include logging your Internet
Protocol (IP) address, software configuration, operating system and use of Cookies.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

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5.

ABOUT COOKIES

5.1.

Cookies are small files containing information that a Website uses to track its visitors, which may besent from us to your computer and sometimes back. Cookies ultimately help us improve your navigationand ease of use of our Online Trading Facility. We may set and access Cookies on your computer,enabling us to learn which advertisements and promotions bring users to our Online Trading Facility.

5.2.

Furthermore, we may use cookies in connection with our products and services to track your activities
on our Website(s).

5.3.

Cookies do not contain any personally identifiable information. Such information, which we may collectand share, is anonymous and not personally identifiable.

6.

SECURITY TECHNOLOGY

6.1.

We protect your Information by using data security technology and using tools such as firewalls anddata encryption. We use ‘Secure Socket Layer (SSL)’ encryption technology in order to protect certain
information that you submit to us. This type of technology protects you from having your informationintercepted by anyone other than us, while it is being transmitted to us.

6.2.

We work hard to ensure that our Websites are secure and that they meet industry standards. We also
use other safeguards such as firewalls, authentication systems (e.g. passwords and personal
identification numbers), and access control mechanisms to control unauthorized access to systems anddata.

6.3.

We also require that you use your personal Access Codes (personal username and password) every time
you access your account online. We restrict access to Information at our offices so that only officersand/or employees who need to know the Information have access to it.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

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7.

SHARING INFORMATION WITH OUR AFFILIATES

7.1.

We may share personal information described above with our affiliates for business purposes, such as,
but not limited to, servicing customer accounts and informing customers about new products andservices, or to aid in the trading activity of the company, its affiliates, or employees, and as permitted
by applicable law.

7.2.

Our affiliates may include companies controlled or owned by us as well as companies that have anownership interest in our company. The information we share with affiliates may include any of theinformation described above, such as your name, address, trading and account information. Our
affiliates maintain the privacy of your information to the same extent as we do, in accordance with thisPolicy.

8.

SHARING INFORMATION WITH THIRD PARTIES

8.1.

We do not disclose your personal information to third parties, except as described in this Policy.

8.2.

In those limited circumstances where we may disclose your personal information to third parties, suchthird party disclosures may include sharing such information with non-affiliated companies that perform
support services for your account or facilitate your transactions with us, including those that provide
professional, legal, or accounting advice to us.

8.3.

Non-affiliated companies that assist us in providing services to you are required to maintain theconfidentiality of such information to the extent they receive it and to use your personal informationonly in the course of providing such services and only for the purposes that we dictate.

8.4.

We may also disclose your personal information to third parties to fulfil your instructions or pursuant
to your expressed consent.

9.
9.1.

REGULATORY DISCLOSURE

Under limited circumstances, we may disclose your personal information to third parties as permittedby, or to comply with, applicable laws and regulations. For example, we may disclose personal
information to cooperate with regulatory authorities and law enforcement agencies to comply with
subpoenas or other official requests, and as necessary to protect our rights or property.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

69.2.

Except as described in this privacy policy, we will not use your personal information for any otherpurpose, unless we describe how such information will be used at the time you disclose it to us or weobtain your permission.

10. CREDIT INFORMATION
10.1. We do not share credit information, such as credit history, net worth, or other income information,
except as otherwise provided herein.

11. RECORDING OF TELEPHONE CONVERSATIONS, E-MAILS,INTERNET CONVERSATIONS (CHAT), MEETINGS AND OTHER
COMMUNICATIONS
11.1. Your telephone conversations, e-mails, internet conversations (chat), meetings and othercommunications with us may be recorded/maintained by us. Any such recordings shall be and shallremain our sole property and will be accepted by you as conclusive evidence of their content as recordedby us.
11.3. You agree that we may deliver copies of transcripts of such recordings to any court, regulatory or
government authority, including without limitation, in disputes which may arise between you and us.
However, technical reasons may prevent us from recording a conversation, and recordings or transcripts
made by us will be destroyed in accordance with our normal practice. Consequently, you should not relyon such recordings to be available.

12. OPT OUT
12.1. You are not required to supply any of the personal information that we may request; however, failure
to do so may result in our being unable to open or maintain your account or to provide services to you.
12.2. While we make every effort to ensure that all information we hold about you is accurate, complete andup to date, you can help us considerably in this regard by promptly notifying us if there are any changes
to your personal information.
12.5. Please be advised, however, that if we receive such instruction we will not be able to service youraccount and must close any open and funded accounts you have.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

713. CLIENT CONSENT
13.1. By accessing and/or using our Website(s) and/or our services, you are consenting to the transmittal ofyour Personal Data (i.e. your personally identifiable Information and your payment details) to oursubsidiaries and to external companies to help us to process and/or analyse it as part of the provisionof our Services to you, whether within or outside the European Economic Area.
13.2. Such Personal Data may also be used for marketing purposes, or to conduct market research for us orother companies in our group that may use such Personal Data to bring to your attention products
and/or services that may be of interest to you and also to assist in the efficient provision of our services,
all in accordance with this Policy.

14. MISCELLANEOUS
14.1. We reserve the right to review and/or amend this Policy and arrangements, at our sole discretion,
whenever we deem fit or appropriate.
14.3. Should you have a question about Privacy and/or Data protection at ‘Traders Trust’, please direct yourquestions to our Compliance Department: compliance@traders-trust.com.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

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