OnFin ltd is responsible for the protection of the privacy and the safeguarding of clients' personal financial information and data. By opening a trading account with the Company, the client hereby gives its consent to such collection, processing, storage and use of personal information by the Company as explained below and in accordance to applicable data protection legislation (including but not limited to the General Protection Regulation (EU) 2016/679 (the "GDPR") and the Data Processing Law.

For the purpose of GDPR and the Data Processing Law, the Company is the data controller.

1. THE COLLECTION OF PERSONAL INFORMATION

The Company collects the necessary information required to open a client's trading account, perform transactions and safeguard the clients' assets and privacy and to provide clients with the services they require. In this respect, the Company may ask clients in certain circumstances, gather information from banks and/or credit agencies,and/or clearing agencies and/or other sources which will help the Company to construct the clients' profile based on their requirements and preferences in order to provide its services effectively. The Company may collect customer's credit card data where is necessary to offer the services the customer opted for.

The information the Company collects includes information required to communicate with and identify its clients. The Company may also collect certain demographic information, including, birth date, education, occupation, etc.The Company also assesses trading related information.

The Company also collects Non-Personal Information, meaning the information which does not allow us to identify the end-user.

The other type of information that we collect is the Personal Information and this allows us to identify the end-user:

1. Identifying documents
2. Documents that we request from you for the proof of identity and your residency. Such information is collected in order to perform transactions through the services provided by the Company at the stage on Due Diligence and might be requested by the Company at any time additionally.
3. Registration information
4. To provide you with our services, at the registration stage we ask you to provide us with your name, e-mail, telephone number.
5. Voluntary information
6. When using our services such as any means of communication with us, we collect the information that you voluntarily provide about yourself.
7. Device data
8. This is the information that we collect from your device and that includes your IP address, unique identifiers and other information that relates to your activity while using the services of the Company.

We may record any communications, electronic, by telephone, in person or otherwise, that we have with you in relation to the services we provide to you and our relationship with you. These recordings will be Company's sole property and will constitute evidence of the communications between the Company and you. Such telephone conversations may be recorded without the use of a warning tone or any other further notice.

2. USE OF PERSONAL INFORMATION

The Company uses clients' personal information only as required to provide quality service and security to its clients. This information helps the Company to improve its services, customize browsing experience and enables it to inform its clients of additional products, services or promotions relevant to clients and in this respect the clients hereby consent to the usage of this data for such purposes.

It shall be noted that the Company may anonymize or de-identify the collected information which, on its own, cannot personally identify you. In addition, the combination of Personal and non-Personal information is considered as Personal information and will be treated so while remaining combined.

The personal data is stored during contractual relationship and after the termination for 5 years and 7 years for taxation purposes.

1. Protection of personal information
2. Any personal information provided by the client to the Company will be treated as confidential and shared only within the Company and its affiliates and will not be disclosed to any third party except under any regulatory or legal proceedings. In case such disclosure is required to be made by law or any regulatory authority, it will be made on a 'need-to-know' basis, unless otherwise instructed by the regulatory authority. Under such circumstances, the Company shall expressly inform the third party regarding the confidential nature of the information.
3. Affiliates and partners
4. The Company may share information with affiliates in the event such information is reasonably required by such affiliate in order to provide the products or services to its clients. The Company may share information with partners, affiliates and associates in order to offer additional similar products and services that meet clients' needs and which are delivered in a manner that is useful and relevant only where clients have authorized the Company to do so.
5. Non-affiliated third parties
6. The Company does not sell, license, lease or otherwise disclose clients' personal information to third parties, except as described in this Policy.
7. The Company reserves the right to disclose personal information to third parties where required by Law, regulatory and other government authority. The Company may also disclose information as necessary to credit reporting or collection agencies as reasonably required in order to provide the services to Company and/or its clients.
8. In addition, the Company may engage third parties to help carry out certain internal functions such as account processing, fulfillment, client service, client satisfaction surveys or other data collection activities relevant to its business. Use of the shared information is strictly limited to the performance of the above and is not permitted for any other purpose. All third parties with which the Company shares personal information are required to protect such personal information in accordance with all relevant legislation and in a manner similar to the way the Company protects the same. The Company will not share personal information with third parties which it considers will not provide its clients the required level of protection.
9. As part of using your personal information for the purposes set out above, non-affiliated third parties are:

• service providers and specialist advisers who have been contracted to provide us with services such as administrative, IT, analytics and online marketing optimization, financial, regulatory, compliance, insurance, research or other services;
• payment service providers and banks processing your transactions;
• auditors or contractors or other advisers auditing, assisting with or advising on any of our business purposes.

3. CONTACT CLIENTS

From time to time the Company may contact clients whether by phone or email for the purpose of offering them further information about the Company and financial market trading.

1. Client's Rights
2. The Company uses all possible means to respect and protect its clients' privacy. At any time, the client may contact the Company and request:

• Right to access, request copy, correct or delete any Personal Information that the Company collected, and which was subject to processing but also the ways how data was obtained, the reason for processing, what data categories were processed and the basis of the automated processing system.
• Right to restrict processing. You have the right to request the restriction or suppression of your personal data. The Company to comply with Laws and Regulations may store the personal data but will not use it.
• Right to object. You have the right to object to the processing of your personal data. The Company may be able to continue processing to comply wit h Laws and Regulations.
• Right to withdraw consent. Where we have obtained your consent to process your personal data you may withdraw this consent at any time. In this case, the Company will be forced to terminate its relat ionship with you within 10 business days.
• Right of erasure. You have the right to request erasure of your personal data. It shall be noted that the Company may refuse to satisfy your request as under any other legal obligations that the Company is subject to, we may be required to keep the information that you provide to us.
• Right for data portability allows you to obtain and reuse your personal data for your own purposes across different services. The Company shall provide such information to you free of charge however, in case of abuse of such right we may charge you a reasonable fee in proportion with your request.

1. In case you disagree with the way we handle your Personal Data and/or you want to exercise any of your rights above, please contact us by sending an e-mail to info@onfin.io and we shall reply to you within 14 calendar days. In the case you have unresolved concerns you have the right to complain to the relevant data protection authority.
2. Marketing
3. The Company may, on occasion, seek to contact clients, whether by phone or by email, for the purpose of informing them of unique promotional offerings provided by the Company for the clients.
4. Any person wishing to opt out of further contact with the Company at any time whatsoever is entitled to do so through the means to decline receiving such promotional offers from use available within the such promotional material. In case you unsubscribe, the Company will remove your contact details from its marketing distribution list.
5. Restriction of responsibility
6. The Company is not responsible for the privacy policies or the content of sites to which the Company links and has no control of the use or protection of information provided by the clients or collected by those sites. Whenever a client elects to link to a co-branded website or to a linked website, the client may be asked to provide registration or other personal information. Please note that such information is recorded by a third party and will be governed by the privacy policy of that third party.

4. COOKIES

The Company uses cookies to secure clients' trading activities and to enhance the performance of the website. Cookies used by the Company do not contain personal information or other sensitive informat ion. The cookies used by the company are:

• "persistent cookies"- only read by our website, are stored on your devise for a fixed time period and are not deleted when the browser is closed. We use these cookies to know who you are for your next visits allowing us to know your preferences the next time you log-in.
• "session cookies"- these are only stored while the browsing session lasts enabling the normal use of the system and are deleted when the browser is closed.

Please note that you may remove the cookies following your browser settings however, disabling of cookies may limit your online experience as well as the functionality of some of the features for the services we provide may be low.

The Company may share website usage statistics with reputable advertising companies and with its affiliated marketing companies. It is noted that the information collected by such advertising companies is not personally identifiable. To administer and improve the website, the Company may use third parties to track and analyze usage and statistical volume information. The third party may use cookies to track behaviour and may set cookies on behalf of the Company. These cookies do not contain any personally identifiable info rmation.

5. UPDATES OF THE POLICY

• The Company reserves the right to update this Policy from time to time. In the event that the Company materially changes this Policy including how it collects, processes or uses clients' personal information, the revised Policy will be uploaded on the Company's website so please review it frequently. In this respect, the clients hereby agree to accept posting of a revised Policy electronically on the website as the actual notice of the Company to its clients. Any dispute over the Company's Policy is subject to this notice and the Client Agreement. The Company encourages its clients to periodically review this Policy so that they are always aware of what information the Company collects, how it uses it and to whom it may disclose it, in accordance with the provisions of this Policy.

Documents regulating our activities