Privacy Policy

This Privacy Policy sets out the way ICC Ihtercertus Capital (Cayman) Ltd (hereafter “The

Company") collects, uses arid manages the personal information received from its visitors,

active ahd/or potential clients who have terminated their business relationship with the

Company who are accessing or using the Company’s website(s) and mobile applications.

The Company is committed to safeguard the confidentiality of your personal information or

data it collects, uses ahd/or holds in accordance with the applicable data protection laws and

regulations and particularly, the provisions of the Cayman Islands Data Protection Laws and

other applicable International Data Protection Regulations like the General Data Protection

regulation of 2016/679 (CDPR) (hereinafter ‘Data Protection Laws’).

Pursuant to the Data Protection Laws, the respective Company with whom you have

registered an account or have a business relationship with is the “Controller” of personal data

collected through https://universalfx.de, mobile applications and other platforms and is the

Company you should contact if you have questions about the use of your Personal Data; The

Company may transfer your personal data to the members ofthe UniversalFx Group of companies

under the Data Protection Laws and is always taking steps to ensure that the processing of

your Personal Data enjoys the same or at least an adequate level of protection.

The Company has established technical and other organisational measures and procedures as

appropriate in order to safeguard and protect your information and privacy as well as to ensure

that the Company manages or processes all personal information in compliance with the

applicable data protection laws and regulations and in accordance with this Privacy Policy.

1. Collection of Personal Data

During the account opening process for a demo or a trading account, you are requested to

complete and submit an application form by providing your personal information. The

provision of the information submitted by you will enable us to evaluate the application and

your eligibility to our services pursuant to the applicable laws and regulations governing the

provision of our services. The same information will be used by the Company to contact you

regarding the offered services.

The Personal Data collected by the Company might include (list not exhaustive):

• your name, surname, address, e-mail address, phone number;
• date of birth, gender, nationality;
• occupation and employment details;
• financial information such as your income, assets and net worth, source of funds;
• tax relevant information as required by FATCA and CPS regime
• IP address and other location data
• bank account information, e—wallets and credit card details in line with due diligence
• procedure and card number and CW should always be hidden/removed;
• documents that you provide to us to verify your identity, such as your passport/identity
• card, utility bills and/or bank statement or your company incorporation details and
• other supporting documents if the applicant is a legal entity.

Other than the information collected directly by you, the Company may also process

information about your transactions with the Company like the products you trade with the

Company and historical data ofyour transactions including, trading history or investments.

The Company is obligated by the regulations to keep your Personal Data on record for a period

of five years which is calculated after the execution of the transactions or the termination of

the business relationship.

2. Lawful basis for the use of Personal Data

The Company collects and process Personal Data which are required for the evaluation,

establishment and maintenance of the contractual relationship between the Company and

the Client and in order to comply with the applicable aforementioned data protection

legislation and regulations governing the provision of investment services, In some cases, the

Company may also process the Client’s Personal Data to pursue its legitimate interests or

those of third parties, provided that the Clients’ interests and fundamental rights are not

overridden by those of the Company or the third party.

In view of the above, the Company may use your personal information for one or more of

the following purposes:

• to confirm/verify your identity;
• to assess your appropriateness/suitability to the products and services we provide;
• to process your transactions;
• to manage the account, you hold with the Company;
• to provide you with transaction and post transaction related services;
• to inform you of products and/or services that may be of interest to you;
• to inform you of amendments of the law affecting our services to you and products as and when required;
• or internal business as well as record keeping purposes;
• to keep you updated on the issues that are relevant to your business relationship with us;
• to analyse statistical data to enable us to provide you with better products and/or services;
• to enhance the security controls of the Company’s networks and systems;
• to identify, assess, mitigate, prevent and investigate fraudulent activity of any kind that is forbidden by the relevant legislation;
• to defend possible legal claims and/or comply with court orders,judicial processes and or any other requirements of a competent authority;

The Company needs to comply with the Anti—Money Laundering regulations, therefore hard

copies and/or in electronic format copies shall be retained as evidence. Also the measures that

are taken by the Company in regards to your identity verification, source of income and wealth,

monitoring of your transactions, telephone/teXt/e—mail communication, and transaction

history must be kept to be able for the Company to demonstrate to the regulator that has

acted in accordance with the legislation.

Ifthere is no lawful basis, for the usage ofyour personal data as indicated above, your consent

will be required. The Companywill askforyour consent in regards to the provision of marketing

information in relation to the products and services offered in accordance with the Client

agreement between the contractual parties and/or any other mean of communication the

Company may use from time to time. Note that you may withdraw such consent at any given

time by sending an email to compliance©everfxglobalcom.

3. Disclosure of Personal Data

The Compa ny shall not disclose to a third party, any of your confidential information unless it

is required to do so by a regulatory authority of a competent jurisdiction, the provisions of

applicable laws and regulations, there is a legitimate interest for such disclosure or duty to do

so or you have requested from us to proceed with a disclosure and/or you have consented to;

such disclosure shall occur on a ‘need—to know' basis, unless otherwise instructed by a

regulatory authority. Provided that such disclosure takes place, the Company shall expressly

inform the third party regarding the confidential nature ofthe information.

Any personal information is treated as confidential and may be shared within the Company

and its partners to meet its contractual and legal obligations. Contractual relationships exist

with the Company’s partners aiming to safeguard the Client’s personal data in accordance

with the Data Protection Laws. Our company partners maintain the privacy of your

information to the same extent the Company does in accordance with the policy. Non—

affiliated companies that assist the Company in providing services to you are required to

maintain the confidentiality of such information and to use your personal information only in

the course of providing such services for the purposes that the Company dictates and within

the ambit ofthe applicable law. It is noted, however, that the use ofyour Personal Data by third

parties is not covered by this Privacy Policy and each of these parties are governed by their

own privacy requirements and procedures.

4. Recipients of Personal Data may be:

• Members of UniversalFx Group of Companies namely ICC Intercertus Capital Ltd and ICC Intercertus Capital (Cayman) Ltd.
• technological experts that appointed by the Company to support the smooth operation of our systems
• platform providers
• payment service provider’s/credit institutions for facilitating the incoming and outgoing payments ofthe Clients
• governmental authorities and regulatory bodies
• fraud prevention agencies, third party authentication service providers, verification/screening service providers
• data reporting service providers to meet our regulatory obligations
• external consultants

5. Transfer Personal Data outside the Cayman Islands

The Company’s aim is to safeguard Personal Data when these are to be transferred outside the

Cayman IslandsAccording to Data Protection Laws, Personal Data can be transferred outside

the Cayman Islands if adequate protective measures are established, appropriate to the

safeguards dictated by Data Protection Laws.

The Company takes appropriate protective measures when Personal Data are disclosed to a

third party. The third parties that the Company may transmit Personal Data shall comply with

the Data Protection Laws or the legislation of their jurisdiction which has equivalent

arrangements.

In particular, you agree to the transfer and/or processing of your Personal Data outside the

Cayman Islands, as described in this section, by providing us with your Personal Data during

the account opening process and the submission of the information required to open and

maintain an account with the Company.

6. Cookies

Cookies are small text files, given ID tags that are stored on your computer’s browser directory

or program data subfolders. Cookies are created when you use your browser to visit a website

that uses cookies to keep track ofyour movements within the site, help you resume where you

left off, remember your registered login, theme selection, preferences, and other

customization functions. The website stores a corresponding file (with same ID tag) to the one

they set in your browser and in this file they can track and keep information on your

movements within the site and any information you may have voluntarily given while visiting

the website, such as email address.

Cookies are often indispensable for websites that have huge databases, need logins, have

customizable themes, other advanced features.

Cookies usually don’t contain much information except for the URL ofthe website that created

the cookie, the duration of the cookie’s abilities and effects, and a random number. Due to the

little amount of information a cookie contains, it usually cannot be used to reveal your identity

or personally identifying information.

There are two types of cookies: session cookies and persistent cookies. Session cookies are

created temporarily in your browser’s subfolder while you are visiting a website. Once you leave

the site, the session cookie is deleted. On the other hand, persistent cookie files remain in your

browser’s subfolder and are activated again once you visit the website that created that

particular cookie. A persistent cookie remains in the browser’s subfolder for the duration

period set within the cookie’s file.

The https://universalfx.de website uses cookies to provide the functionality you need to

browse our site correctly. The https://universalfx.de website issues cookies upon landing on

our website, unless the user has changed their cookie settings in their browser to refuse

cookies. Please note that with cookies switched off, some areas of our website and services

might not be made available to you.

The Company does not use cookies to personally collect information about you 7 the cookies

that we use only collect anonymous information to optimize our services and do not collect

personal information.

Ifyou require additional information about how the Company uses Cookies on its website, you

may refer to the Company's Cookies policy uploaded on the Company's website here.

7. Security

The privacy and confidentiality of your personal information is of fundamental importance to

us. We take all appropriate security measures to protect against unauthorized access to or

unauthorized alteration, disclosure or destruction of data and personal information.

We restrict access to personal information to employees who need to know the specific

information in order to operate, develop or improve our services. These individuals are bound

by confidentiality and will be subject to penalties If they fail to meet these obligations.

Also the Personal Data can be shared only with the parties set out in the aforementioned

section for Disclosure of Personal Data.

The Personal Data that you provide in connection with opening an account (appropriateness

/suitability test) with the Company are highly protected. This information can be accessed only

byyou using your own selected password and logins.The Company strongly recommends that

your password is carefully kept and not to be shared with any third party. In addition, this

information is safely stored in the Company’s servers that only authorized personnel have

access to it through access rights. The Company encrypts all this information to prevent

unauthorized parties from viewing or access such information.

8. Personal Data Rights

You have the following rights in respect of your Personal Data in accordance with the Data

Protection Laws:

• Right of Access: You have the right to be informed whether and under which
• Circumstances the Company is processing your Personal Data and the
• Company is required to provide you with a copy of your Personal Data if and when you request so.
• Rectification Right: You can request to amend your Personal Data in order to correct or complete the provided Personal Data (up to date information),
• Erasure Right: You can request to delete/remove your Personal Data under certain circumstances, for instance if your consent has been withdrawn. The effect of such request is always subject to any other requirements imposed by applicable laws and regulations.
• Right to Restrict Processing: You may request from the Company to restrict the processing ofyour Personal Data if it is not accurate, it has been used unlawfully or it is not relevant anymore. The said right is not an absolute right and only applies in certain circumstances. In addition, when processing is restricted, the
• Company is still permitted to store the Personal Data, but not use it.
• Right to Data Portability: You may request to obtain your Personal Data in a readable format for your own purposes.
• Right to Object: You may request from the Company to stop processing your
• Personal Data, and the Company will do so if: a) the Company cannot demonstrate compelling legitimate grounds for the processing or b) the
• Company is processing Client’s Personal Data for marketing purposes.
• Right to Withdraw Consent: You can withdraw any consent given to the
• Company at any time where the Company relies on consent to process your
• Personal Data Right to complain,

9. Communication with the Company

You may exercise any of the above rights by contacting the Company as follows:

• By sending an emailto:compliance©everfxglobalcom or
• by post at postal address: Artemis House, Fort Street, KYI—III, Grand Cayman, Cayman Islands

10. Changes to the Privacy Policy

The Company reserves the right to change or amend the Privacy policy without further notice

to you, provided that the Changes do not significantly reduce your rights under this Policy. If

we make material changes to this policy, we will notify you by email or by means of a notice

on our home page or by Changing the version of the document including the date of the

update which will be visible to the first page ofthis document. The latest and prevailing version

of this Policy will at all times be available at https://www.even°xglobal.com. Any revised Policy

will be effective immediately upon posting on our Web Site.

11. Legal Disclaimer

The Company reserves the right to disclose your personally identifiable information as required

by rules and regulations and when the Company believes that disclosure is necessary to

protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal

process served. The Company will not be liable for misuse or loss of personal information

resulting from cookies on the Company’s siteIs) that the Company does not have access to or

control over. The Company will not be liable for unlawful or unauthorized use of your personal

information due to misuse or misplacement of your passwords, negligent or malicious.

Further information on the Company's Privacy Policy is available upon request. The

Company’s contact details are:

Tel.: + 0013457695571 or 00380893240717

E—mail: support©universalfx.de

Address: Artemis House, Fort Street, KYI—III, Grand Cayman, Cayman Islands