Privacy Policy Last Updated: 24/02/2024

We (hereinafter referred to as “we”, “us” or “the Company”) are committed to protecting your personal data and privacy.

This Privacy Policy explains how we manage, collect, store and use the information you provide when using the Finoryx AI website (the “Website”).

We are committed to the following principles:

• Ensuring transparency when collecting and processing your personal data:

We prioritise keeping you fully informed so you can make informed decisions about the use of your personal data on our website or when trading with third-party platforms. To achieve this, we employ various strategies and methods to provide you with relevant details about how your personal data is processed, ensuring the information is accurate and delivered in a timely manner.

Additionally, where specific information needs to be provided to you, we will ensure it is delivered at the appropriate time and place.

We are also happy to answer any questions you may have and provide clarification within legal limits. For enquiries, please feel free to contact us at any time via the following email: [email protected]

• Processing your personal data only for the purposes stated in this Policy:

We process your personal data for purposes including but not limited to: providing you with the website and connecting you with third-party trading platforms (the “Services”), enhancing your experience on the website, optimising the Services (including the website), protecting our rights and interests, carrying out support activities for the provision of services to website users, and/or complying with any legal and/or regulatory obligations.

We may also process your personal data to better understand your individual needs and preferences.

• Investing significant resources to respect your rights regarding personal data:

We invest considerable resources to enable you to exercise your rights as a data subject. Therefore, if you wish to access your personal data, request that we correct, delete, stop using it for specific purposes or cease processing it entirely, or transfer the data to you or a third party, please contact us at any time. We will handle your request in accordance with the law.

• Protecting your personal data:

While we cannot guarantee absolute security of your personal data, we assure you that we have implemented and will continue to implement a range of comprehensive methods and measures to ensure your personal data is protected.

Our Full Privacy Policy

1. Scope?

This Policy outlines the types of personal data the Company collects and the methods used for collection, use, sharing with third parties, protection and processing.

In this Policy, “personal data” means any information relating to an identified or identifiable individual. An identifiable individual is one who can be identified, directly or indirectly, by reference to additional information available to us.

In this Policy, “processing” of personal data means any operation or set of operations performed on personal data, including collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Our services are directed at a general audience and are not intended for children under 18 years of age. We do not knowingly collect or solicit information from anyone under 18, nor do we knowingly allow such persons to access our services. If we become aware that we have collected information about a child, we will take reasonable steps to delete such information promptly.

2. When do we collect personal data about you?

We collect personal data about you whenever you use the Services, interact with service channels and access the website. Sometimes you provide personal data to us directly; in other cases, we collect it by examining and analysing your interactions with our services and/or service channels, or we receive it from our third-party partners.

3. No obligation to provide personal data to Finoryx AI and its consequences

You are not required to provide us with any personal data about yourself. However, in certain cases, failure to provide such personal data may prevent us from providing you with the Services, stop you from using the website, and/or cause malfunctions in the Services and website.

4. What types of personal data do we collect? Personal data we collect each time you visit the website:

This includes online activity logs, traffic information (including but not limited to IP address, time and date of access, pages and mobile pages visited, language used, software crash reports, browser type used, and information about the device you are using). Some of this information may not identify you personally and may therefore not be considered personal data.

Personal data we receive from you: Any personal data you voluntarily provide to us when interacting with third-party trading platforms through our website.

Personal data you specifically provide to submit to third-party platforms to facilitate trading: This includes your full name, phone number and email address.

5. Purposes for processing personal data and legal basis

Finoryx AI processes your personal data for one or more of the purposes detailed in this section, each supported by an appropriate legal basis.

Finoryx AI will not process your personal data unless there is a valid legal basis. The legal bases on which Finoryx AI processes your personal data include:

You have given consent for the processing of your personal data for one or more specific purposes. This applies when you deliberately share your information through the website, allowing us to submit it to third-party trading platforms.
Processing is necessary for the legitimate interests pursued by Finoryx AI or by a third party. For example, this may include improving our services or managing legal claims.
Processing is necessary for compliance with a legal obligation to which Finoryx AI is subject.

If you require further clarification on how the processing of your personal data serves the legitimate interests of Finoryx AI or other parties, please contact us by email at any time.

The table below summarises the reasons we may process your personal data and the legal basis for each activity:

	Purpose	Legal Basis
1	Forwarding your information to third parties upon your request for participation in digital and trading activities. We may collect personal data about you in order to forward it to third parties when you explicitly request this action.	You have given consent for the processing of your personal data for one or more specified purposes.
2	Handling your enquiries, requests and/or concerns Processing your personal data is necessary to handle any enquiries you may make regarding the use of our services.	Processing is necessary for the legitimate interests pursued by the Company or a third party.
3	Compliance with any legal obligations or court and administrative orders We process your personal data to ensure compliance with our various legal obligations.	Processing is necessary for compliance with a legal obligation to which the Company is subject.
4	Improving our services We may use your personal data to refine our services. This processing includes analysing crash logs or any other fault reports related to the services.	Processing is necessary for the legitimate interests pursued by the Company or a third party.
5	Preventing fraudulent activity and abuse of our services	Processing is necessary for the legitimate interests pursued by the Company or a third party.
6	Carrying out and maintaining various activities that support the provision of our services Such operations include back-office tasks, business development planning, strategic planning, monitoring processes, etc.	Processing is necessary for the legitimate interests pursued by the Company or a third party.
7	Performing analytics, including statistical assessments We apply various analytical techniques, including statistical methods, to inform decision-making on a range of matters.	Processing is necessary for the legitimate interests pursued by the Company or a third party.
8	Protecting our and third parties’ interests, rights and assets, including establishing, exercising or defending legal claims We may process your personal data to defend the interests, rights and assets of us or third parties in accordance with any law, regulation or agreement (including any of our terms, conditions and policies).	Processing is necessary for the legitimate interests pursued by the Company or a third party.

6. Transfer of personal data to third parties

Finoryx AI may also disclose your personal data to third-party service providers that assist us with storage, hosting, IP address information, user experience analytics, research and other analytics, technical and diagnostic services.

In addition, if you specifically request it, we may transmit certain personal data about you to third-party trading platforms. In such cases, we will share with these third parties the information you provide for this purpose, and they will process your personal data in accordance with their own privacy policies. We may share your personal data with multiple third-party trading platforms.

Finoryx AI may also share your personal data with its affiliated entities and business partners that provide resources to enhance and optimise the quality of services and products we offer to users.

We may disclose your personal data to government, local, official and regulatory authorities where such disclosure is necessary to protect our and third parties’ interests, rights and assets (including establishing, exercising or defending legal claims).

We may also release personal data about you to potential buyers, investors or lenders of Finoryx AI or any company in our group, or in connection with any similar transaction (such as the sale of assets), or in relation to any merger, reorganisation, consolidation or bankruptcy involving Finoryx AI or any affiliated company.

7. Cookies and third-party services

We may use certain third-party services, such as analytics companies or advertising providers on our website, which may also use cookies or other technologies. These practices and providers are governed by their own policies.

A cookie is a small text file installed on the device you use to access the website. These cookies are able to collect information about you and your behaviour in order to

enhance the user experience by remembering your preferences and settings, and to customise products and services that may be of interest to you. Cookies may also be used to collect statistical data and perform analytics.

Some of the cookies we use may be session cookies, which are temporarily downloaded to your device and remain active until you close your web browser. Others are persistent cookies, which remain on your device after you stop browsing the website and help the website recognise you as a returning visitor.

Types of Cookies:

The cookies we may use are categorised according to their function as follows:

Cookie Type	Purpose	Additional Information
Strictly Necessary Cookies	These cookies are essential to enable you to browse the website and use the features you request. They ensure the delivery of the content, products and services you are looking for. These cookies are essential for downloading or streaming information to your device, allowing you to browse the website seamlessly, use its features and return to previously visited pages.	These cookies collect personal data about you, such as your username and last login date, and confirm your logged-in status on the website. These cookies are automatically deleted when you close your web browser (session cookies).
Functional Cookies	These cookies help us recognise you when you return to the website, allowing us to remember your choices and preferences.	These cookies remain active even after the browser is closed, until the set expiry time.
Performance Cookies	These cookies are essential for collecting aggregated statistical data about website performance, helping to test and improve the website to provide an excellent user experience. They also allow us to perform analytics functions on the website.	These cookies collect anonymous data that cannot be traced back to any identified or identifiable individual. The validity period of these cookies varies; some are deleted when you close your browser, while others are retained indefinitely.

Blocking and Deleting Cookies

You can adjust your browser settings to block and delete some or all cookies. Below are links to instructions for some of the most commonly used web browsers:

Firefox
Microsoft Edge
Google Chrome
Safari

Please note that if you continue, some features and functions of the website may not work as expected.

Online Tracking Notice

Currently, this service does not support “Do Not Track” signals.

8. Retention of your personal data

Finoryx AI will retain your personal data for as long as necessary to fulfil the purposes described in this Policy or as required by applicable laws, regulations, policies and orders.

We will share your information with third-party trading platforms within 12 months, and with your consent, we may extend this by another 12 months.

To ensure your personal data is not retained longer than necessary, we regularly review the data we hold to determine whether any data can be deleted.

9. Transfer of personal data to third countries or international organisations

Your personal data may be transferred to third countries (i.e. outside your jurisdiction) or international organisations. In such cases, Finoryx AI will implement appropriate safeguards to ensure your personal data is protected and enforceable data subject rights and effective legal remedies are available.

If you are located in the European Economic Area (EEA), please note that the following safeguards will be implemented if any of the following conditions are met:

The transfer is to a third country or international organisation that the European Commission has determined provides an adequate level of protection for personal data, in accordance with Article 45(3) of the GDPR.
The transfer is made pursuant to a legally binding and enforceable agreement between public authorities or bodies, as referred to in Article 46(2)(a) of the GDPR; or
The transfer complies with the standard data protection clauses adopted by the European Commission pursuant to Article 46(2)(c) of the GDPR. You can view these clauses at: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

If you are interested in learning about the safeguards we use to protect personal data transferred to third countries or international organisations, please contact us by email: [email protected]

10. Protection of your personal data

We seriously implement appropriate technical and organisational measures to ensure a high level of security for personal data, taking into account the risks involved in the processing, in particular the risk of accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

While we strive for perfection, we cannot guarantee error-free performance regarding the privacy of your personal data. We are not liable for indirect, incidental, consequential or punitive damages related to the use or release of your personal data, including but not limited to disclosure of personal data due to transmission errors, unauthorised third-party access or other causes beyond our reasonable control.

In some cases, legal or other obligations beyond our control may require us to transfer your personal data to third parties, such as public authorities. In these situations, we have limited control over the level of protection third parties provide for your personal data.

Transmission of personal data over the internet cannot be completely secured. Therefore, Finoryx AI cannot guarantee the security of your personal data when it is transmitted to us over the internet.

11. Links to third-party websites

The website may contain links to websites and/or applications operated by third parties. Finoryx AI does not supervise these websites and applications, nor does it supervise their collection and/or processing of your personal data. We are not responsible for these websites and applications or their privacy and data protection policies and practices. This Policy does not govern any activities conducted through such websites and/or applications.

Whenever you access these third-party websites and/or applications, we recommend that you carefully review their privacy policies before use and before sharing any personal data.

13. Your rights regarding personal data

In general, you have the right to request that we confirm whether we are collecting personal data about you, access this data, correct any inaccuracies, and delete personal data we no longer need. You can also restrict your consent to specific processing of personal data.

If you are a resident of the European Economic Area, please refer to this section:

You have the following rights regarding your personal data. To exercise these rights, you can send a request to exercise your rights to the following email address:

Right of Access

You have the right to obtain from Finoryx AI confirmation as to whether your personal data is being processed, and if so, access to the personal data and the following information: (1) the purposes of the processing; (2) the categories of personal data concerned; (3) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations outside the EEA; (4) where possible, the envisaged period for which the personal data will be stored, or if not possible, the criteria used to determine that period; (5) the existence of the right to request rectification or erasure of personal data or restriction of processing, or to object to such processing; (6) the right to lodge a complaint with a supervisory authority; (7) where the personal data are not collected from you, any available information as to their source; (8) the existence of automated decision-making, including profiling; and (9) where personal data are transferred to a third country or international organisation outside the EEA, the appropriate safeguards relating to the transfer.

Finoryx AI will provide a copy of the personal data undergoing processing and may charge a reasonable fee for any additional copies requested. Where the request is made by electronic means and you do not request otherwise, the information will be provided in a commonly used electronic format.

The right to obtain a copy of personal data shall not adversely affect the rights and freedoms of others. Therefore, if the request would adversely affect the rights and freedoms of others, Finoryx AI may choose not to fulfil your request or to fulfil it in a restricted manner.

Right to Rectification

You have the right to request that Finoryx AI rectify any inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Right to Erasure

This right applies on the following grounds: (a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (b) you withdraw consent and there is no other legal basis for the processing; (c) you object to the processing of your personal data based on our or a third party’s legitimate interests and there are no overriding legitimate grounds for the processing; (d) you object to the processing of your personal data for direct marketing purposes; (e) the personal data have been unlawfully processed; or (f) the personal data must be erased for compliance with a legal obligation under EU or Member State law to which the Company is subject.

This right does not apply to the extent that processing is necessary (a) for compliance with a legal obligation under EU or Member State law to which the Company is subject; or (b) for the establishment, exercise or defence of legal claims.

Right to Restriction of Processing

You have the right to request that the Company restrict the processing of your personal data in the following cases: (a) you contest the accuracy of the personal data, for a period enabling the Company to verify its accuracy; (b) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of its use instead; (c) the Company no longer needs the personal data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims; (d) you have objected to processing which is based on the legitimate interests of the Company or a third party, pending verification whether the legitimate grounds of the Company override your interests, rights and freedoms; or (e) your personal data is processed for direct marketing purposes, including profiling, insofar as it is related to such marketing.

Where processing has been restricted on the basis of your request, such personal data (except for storage) shall only be processed with your consent or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the EU or of a Member State.

Right to Data Portability

You have the right to receive the personal data you have provided to the Company in a structured, commonly used and machine-readable format. In addition, where the processing is based on your consent or on a contract to which you are a party and the processing is carried out by automated means, you have the right to have this data transmitted to another entity.

When you exercise the right to data portability, it is possible for your personal data to be transmitted directly from the Company to another organisation, provided this is technically feasible. This right does not affect your or the Company’s right to delete the data. Furthermore, the exercise of this right shall not adversely affect the rights and freedoms of others.

Right to Withdraw Consent

You have the right to withdraw your consent to our processing of your personal data at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

Right to Object

You may object at any time to the processing of your personal data, particularly where it relates to your particular situation and the processing is based on the legitimate interests of the Company or a third party. This includes any profiling carried out on that basis. Once you object, we will stop processing your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.

In addition, you may object at any time to the processing of your personal data for direct marketing purposes, including any related profiling.

Right to Lodge a Complaint with a Supervisory Authority

You have the right to lodge a complaint with a supervisory authority established by a Member State in order to protect the fundamental rights and freedoms of natural persons in relation to the processing of personal data within the EU.

Your rights regarding personal data as detailed in Section 13 of this Policy may be subject to restrictions under EU or Member State law to which the Company is subject.

We will provide you with the requested information in relation to the rights detailed in Section 13 of this Policy without undue delay and in any event within one month of receipt of the request. Where necessary, taking into account the complexity and number of requests, this period may be extended by a further two months. We will inform you of any such extension within one month of receipt of your request, together with the reasons for the delay.

The information requested under the rights detailed in Section 13 of this Policy will be provided free of charge, unless otherwise stated in this section. Where requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may (a) charge a reasonable fee taking into account the administrative costs of providing the information, communication or taking the action requested; or (b) refuse to act on the request.

Finoryx AI may request additional details necessary to verify the identity of the person making the request in order to process requests made under the rights described in Section 13 of this Policy, particularly where there is reasonable doubt concerning the identity of the individual making the request.

12. Updates to this Policy

We reserve the right to modify this Policy from time to time. Whenever changes are made, we will notify you by posting the revised Policy on the website. In addition, for material updates, we will endeavour to notify you of such changes through communication methods we deem reasonably effective, and post a notice on the website. Unless otherwise stated, all modifications will become effective upon posting of the updated Policy on our website.