Updated and Effective Date: June 28, 2021 Tower Research Capital LLC and its affiliates (collectively, “Tower Research Capital”, “we”, “our” or “us”) are committed to protecting your personal information when you use our website. Our privacy notice sets out the personal information we collect, the purposes for which personal information is collected and processed, who it may be disclosed to, and your individual rights. How we obtain your information We may collect personal information from you when you use our website or engage in communication with us for example, submitting an employment application or contacting us when you use the email address on our website. We collect information from a variety of sources, including: any documents you submit to us, including application forms, CVs or resumes, your passport or other identity documents; your use of our website (including usage data through the use of browser cookies or other commonly used technologies such as web beacons and IP information); our communication or correspondence with you, such as when you contact us by email or by post; from third parties in connection with potential employment such as recruiting agencies, employers, online platforms including professional and social networks and forums, employment background check providers, criminal records check providers, educational institutions, financial institutions, service providers and other individuals; or from other third parties in connection with your use of our website. The information we collect your name, address and contact details, including email address and telephone number; identification numbers, such as your passport number or government-issued ID number; details of your qualifications, skills, experience and employment history; information about your current level of remuneration, including benefit entitlements; whether or not you have a disability for which the company needs to make reasonable adjustments during the recruitment process; information about your entitlement to work; equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or beliefs; other information you or others may provide to us during your communications with us; and your browser, device type, IP address, and user session information. You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all. Further, we will seek information from third parties only once a job offer to you has been made and will inform you that we are doing so. You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information. Our use of your information We process your information where we have a legitimate interest (e.g., for recruiting purposes), if it is required for contractual or operational reasons, if required by applicable laws or regulations or on the basis of your consent. Where we process “special categories” or information about you, we do so on one of the following bases: your explicit consent (which can be withdrawn at any time), legal or regulatory requirements, health and safety, monitoring of equality and diversity, or prevention or detection of crime. How we share your information We may share your information within the Tower Research Capital family of companies, with our third party service providers, and other third parties for the purposes set out below. Within Tower Research Capital: Your information will be shared internally for the purposes of the recruitment exercise. We may share your personal information within Tower Research Capital. This includes members of the Tower Research Capital human resources and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles. Third party service providers: We will share personal information with third parties who perform services on our behalf. For example, we share personal information with our vendors (e.g., IT services providers, cloud providers, background check vendors, online platforms, recruiting agencies and platforms), partners and consultants. We may also share personal information with companies that operate our website. Legal reasons: We will share personal information if we think we have to in order to comply with the law or to protect ourselves such as responding to court orders or subpoenas. We may also share your personal information if a government agency or investigatory body requests. We may also use your personal information when we are investigating potential fraud or other areas of concern or if we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others. Rights for individuals in the European Economic Area and the United Kingdom Individuals who are located in or residents of countries in the European Economic Area (“EEA”) and the United Kingdom (“UK”) have certain data subject rights that may be subject to limitations and/or restrictions. You may have the following rights under data protection laws: Right of subject access: The right to access and obtain a copy of your data on written request; Right to rectification: The right to have incorrect or incomplete data rectified; Right to erasure: The right to have certain personal data about you erased; Right to restriction of processing: The right to require we delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; Right to object: The right to object to the processing of your data; Right to data portability: The right to ask for personal data you have made available to us be transferred to you or a third party; and Right to withdraw consent: The right to withdraw any consent you have previously given us to handle your personal data, provided that this will not affect the lawfulness of our use of your data prior to the withdrawal of your consent. These rights are not absolute; they do not always apply and exemptions may be applicable. You may have the right to lodge a complaint about the processing of your personal information with your local data protection authority. If you would like to exercise any of these rights, please contact our Head of Compliance EMEA (compliance@tower-research.com). For the purposes of EEA and UK data protection laws, we are the data controller of your personal information collected on our website. This means that we are responsible for, and control the processing of, your personal information. Security and retention We maintain reasonable security procedures and practices but the internet is not 100% secure. We cannot promise that your use of our website will be completely safe. We encourage you to use caution when transmitting personal information over the internet. We will hold your personal information on our systems for the longest of the following periods: as long as it is necessary or relevant for the practices described in this Privacy Notice; or as long as is required by law or for internal compliance or record-keeping purposes. How we transfer and store your information In connection with our business and for employment, administrative, management and legal purposes, we will where necessary and as set out in this Privacy Notice transfer your personal data outside the EEA and UK to members of Tower Research Capital in other jurisdictions in which we are established. We will ensure that any transfer is lawful and that there are appropriate security arrangements. In relation to intra-group transfers, the members of Tower Research Capital have entered into agreements ensuring appropriate and suitable safeguards with the Tower Research Capital group’s controllers/processors outside the EEA and UK. These are in standard terms approved by the European Commission. If you wish to see details of these safeguards, please ask of Head of Compliance EMEA (compliance@tower-research.com). Automated decision making Recruitment processes are not based solely on automated decision-making. Contact us If you have any questions about this Privacy Notice or other privacy concerns, please contact us at: Tower Research Capital LLC 377 Broadway 11th Floor New York, NY 10013 Attn: Data Protection Officer DPO@tower-research.com We may update this Privacy Notice From time to time we may change our privacy policies. We will also post an updated copy on our website so please check periodically for updates. You are bound by any changes to the Privacy Notice when you use the website after such changes have been first posted. NEW YORK . CHICAGO . CHARLESTON . MONTREAL . LONDON . AMSTERDAM . GURGAON . GIFT CITY . SINGAPORE . HONG KONG . 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