PEAK WEALTH PTY LTDPRIVACY POLICY

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Regulated by the Financial Sector Conduct Authority (FSCA)
Authorised Financial Service Provider (FSP) Number 44681 - Registration Number 2013/007163/07

TABLE OF CONTENTS
Contents
1. Introduction ........................................................................................................................................ 3
2. Personal Information we collect ......................................................................................................... 3
3. Lawful possession and processing of Personal Information ............................................................... 4
4. Information required to be collected by law: Identification .............................................................. 4
5. Disclosure of Personal Information .................................................................................................... 56. Purpose and Retention of Personal Information ................................................................................ 67. Security and Integrity of Personal Information .................................................................................. 78. Your rights in connection to Personal Information............................................................................. 79. Restriction of Responsibility ............................................................................................................... 810. Consent to process Personal Information ........................................................................................ 811. Changes and Updates to this Privacy Policy ..................................................................................... 8Page | 2
Regulated by the Financial Sector Conduct Authority (FSCA)
Authorised Financial Service Provider (FSP) Number 44681 - Registration Number 2013/007163/07

1. Introduction
Peak Wealth (Pty) Ltd (hereinafter “the Company”, “us”, “our” “we”) is incorporated in South Africa
andregistered
under
theCompaniesandIntellectual
Property
Commission(http://www.cipc.co.za/za/) with a registration number 2013/007163/07. The Company is authorised
and regulated by the Financial Sector Conduct Authority (“FSCA”) with authorisation number
FSP44681, to provide intermediary services in connection with derivative products, operating under
the Financial Advisory and Intermediary Services Act (“FAIS Act”).

Privacy is very important for us, and we are committed to protecting and respecting your personal
data. The development of a standard operating procedure to ensure the effective protection of client
and/or user information as well as the development of operations and risk management is of theutmost importance to us.

Personal information which are processed by the Company is done so in accordance with theprovisions of the Protection of Personal Information Act 4 of 2013 (“PoPI Act”), the provisions ofInternational Principles of Information Protection and the Basic Provisions of the Constitution of South
Africa 1996.

2. Personal Information we collect
As per the PoPI Act’s definition of Personal Information: “information relating to an identifiable, living
natural person, and where it is applicable, an identifiable, existing juristic person, including but notlimited toa) information relating to the race, gender, sex, pregnancy, marital status, national, ethnic orsocial origin, colour, sexual orientation, age, physical or mental health, well-being, disability,religion, conscience, belief, culture, language and birth of the person;b) information relating to the education or the medical, financial, criminal or employment historyof the person;c) any identifying number, symbol, e-mail address, physical address, telephone number, location
information, online identifier or other particular assignment to the persond) the biometric information of the person;e) the personal opinions, views or preferences of the person;f) correspondence sent by the person that is implicitly or explicitly of a private or confidential
nature or further correspondence that would reveal the contents of the originalcorrespondence;g) the views or opinions of another individual about the person; andh) the name of the person if it appears with other personal information relating to the person orif the disclosure of the name itself would reveal information about the person”

The following personal data of customers, potential customers and other users of the website andplatform include:Name, Surname, and contact details
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Regulated by the Financial Sector Conduct Authority (FSCA)
Authorised Financial Service Provider (FSP) Number 44681 - Registration Number 2013/007163/07

Information about income, wealth, assets and liabilities, other account balances, history oftrading statements, tax and other financial statements.
Profession, employment status and other employment related details.
Location Information, jurisdiction, residency and nationality.
Knowledge and experience in trading and risk tolerance questions.
IP address, device specifications.
Bank account, e-wallets, credit card details.

The above information is either obtained directly from you or, unless required by law, obtained fromanother source.

3. Lawful possession and processing of Personal Information
The Company shall ensure that all the conditions set in the PoPI Act are complied with regarding thepurpose and method of processing of Personal Information. Any data shared with the Company will
be processes for the purposes within which they were shared and the process sha remain adequate
relevant and not excessive.

Personal Information shall only be processedwith the prior consent of the user, or
if it is necessary for us to carry out actions for a performance of our contract with the user, orto remain compliant with the processing obligations imposed by the law, orto protect the legitimate interests of the user, orif is necessary for the performance of public law duty set by a public body, orPersonal Information may be collected and held about:

website visitors/potential clients
service providers and other third parties
current and potential employees
other people who come in contact during the course of business.

4. Information required to be collected by law: Identification
We are required under the law to identify any person who opens an account with us, or any new
person who becomes a signatory to an existing account. The Anti-Money Laundering laws require us
to record certain documents to meet the standards as these are set by the law. The documents that
we collect, and store are:a) passport;b) driver’s licence;
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Regulated by the Financial Sector Conduct Authority (FSCA)
Authorised Financial Service Provider (FSP) Number 44681 - Registration Number 2013/007163/07

c)
d)
e)
f)
g)

national identity card (if applicable);utility bills;
trust deed (if applicable);a credit check on the individual; orother information we consider necessary to our functions and activities.

Corporate clients are required to provide further documents and information, such as the corporate
documents of address, shareholder information, directors, other officers and the personal informationof all of the abovementioned.

Obtaining the above information can happen through different ways, in which we see fit to be able toprovide our services such as through the account opening process, demo sign up, website cookies,
subscription to our email services and any other way form that information was shared for the courseof our ongoing relationship.

Personal Information may also be collected through third-parties such as publicly available lists, social
media, introducing brokers or affiliates, banks and other credit institutions, intelligence databases andother third-party associates.

5. Disclosure of Personal Information
All personal information shall be kept confidential; however, they may be disclosed to third parties as
we may be required to do so by law. Third parties with which we have entered into contractual
agreement with, will be obliged to apply data protection measures and confidentiality.
Such third parties may include:
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Services providers chosen by the Company to support in the effective provision of our services(e.g. Tech Support, expertise etc).
Court of Law.
The Regulator.
Anyone the user/client has authorised to the disclosure of their personal information.
External professional advisors and consultants, including but not limited to legal, accounting
and tax consultants.
Governmental and regulatory bodies and authorities including enforcement authorities suchas the FSCA.
Organisations involved in the potential transfer or sale of the Company’s operations.

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Authorised Financial Service Provider (FSP) Number 44681 - Registration Number 2013/007163/07

6. Purpose and Retention of Personal Information
Due to the nature of our Company’s operations the Personal Information are collected for thefollowing, but not limited to, the following purposes:
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To conduct our business of intermediation in relation to CFDs and other derivative products.
To provide users and individuals with information about the products, services andpromotions.
Protect the users and clients from fraudulent and unlawful activity.
To enhance the security of the Company’s information systems.
To maintain accounts and records.
To investigate and resolve any queries, complaints and/or concerns any user or client or
individual has.
To manage any legal issues that involve the Company.
To comply with our legal and regulatory obligations
To help us enhance and manage our services.
To obtain professional advice (e.g. legal or otherwise)
For statistics purposes, such as website unique visitors and users.

Records are retained as a legal obligation as set by the applicable regulation and may be retained
longer than is necessary for achieving compliance. This may be because:Is required by law
The company has reasonable grounds to believe that there are lawful purposes to hold theinformation to be able to perform its functions or activities.
Retention of the data is a contractual obligation between the parties.
The user/client has consented to the retention of the Personal Information.

We hold personal information in a combination of secure computer storage facilities and paper-based
files and other records and take steps to protect the personal information we hold from misuse, loss,
unauthorised access, modification, or disclosure.

The records must be maintained for a period of five years after our business relationship with theuser/client has ended or for a further period, as this may be requested by the regulator or change inregulation/legislation.

When we consider that personal information is no longer needed, we will remove any details that will
identify you or we will securely destroy the records. The Company will also destroy or delete any
record of personal information as soon as reasonably practicable after it is no longer authorised toretain the record. The destruction of such records must be done in a manner that it prevents thereconstruction in an intelligible form.

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Regulated by the Financial Sector Conduct Authority (FSCA)
Authorised Financial Service Provider (FSP) Number 44681 - Registration Number 2013/007163/07

7. Security and Integrity of Personal Information
Respecting the privacy of our users is our top priority and we therefore take all reasonable steps toensure that information shared with us are safeguarded. We have set the necessary and appropriatetechnical and organisational measures to ensure that all information remains secured. Furthermore,
we make sure that any person(s) responsible for handling client information and data are trained andaware of the importance of maintaining and keeping client data safe and privacy respected at all times.

Transmission of information over the internet is not always completely secure, but the Company takeprecautions to protect the personal data and establishes procedures and security features to prevent
unauthorised access.

If in the unfortunate event there are any breach of security regarding client data and information, we
notify the Regulator and the affected users/clients as soon as reasonably possible by any means
appropriate in the circumstances to enable all involved parties to take the necessary steps to protect
their interests.

8. Your rights in connection to Personal Information
You have the right to be notified if any of the Personal Information you shared with us has access or
acquired by an unauthorised person. You also maintain the right to request and obtain a copy of all
the personal information that the Company holds on you.

As the personal information belongs to you, you may request for the destruction of such personal
information to the extent permitted by law, as we are required to remain compliant with ourregulatory obligations for personal information retention.

You may also object within reasonable grounds relating to a particular situation to the processing ofyour Personal Information. You may also object to the processing of your Personal Information for thepurposes of direct marketing and other electronic communications.

You are also within your rights to submit a complaint with the Information Regulator for any alleged
misuse of mistreating of your Personal Information as this is found at https://justice.gov.za/inforeg/To exercise any of the above rights, or any questions and queries you may have about this policy please
get in touch with us at support@xtrade.com

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Regulated by the Financial Sector Conduct Authority (FSCA)
Authorised Financial Service Provider (FSP) Number 44681 - Registration Number 2013/007163/07

9. Restriction of Responsibility
The Company does not hold any responsibility and shall not be held responsible for the Privacy Policies
of any other third-party company, or partner that may be linked to it. The company also has no control
on how Client information will be used by such third-parties or partners.

10. Consent to process Personal Information
By accessing our website and using any method of communication as this is available to you, weconsider that you haver read and understood this Policy and now we process any information that you
disclose to us, including but not limited to personal information prior to becoming a client of theCompany.

11. Changes and Updates to this Privacy Policy
This Privacy Policy is reviewed once a year taking into account the changes in local and international
legislation but also the changing environment and advances in technologies. This is to ensure that itremains appropriate to the changing environment.
We suggest and encourage our clients to periodically review this Privacy Policy document so that they
are aware of any changes and how their information is affected following the aforementionedchanges.

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Regulated by the Financial Sector Conduct Authority (FSCA)
Authorised Financial Service Provider (FSP) Number 44681 - Registration Number 2013/007163/07