1. INTRODUCTION

This privacy notice applies to the processing activities performed by ATS Interface to the PERSONAL DATA of its clients, prospective clients, and website visitors. Your privacy is of the utmost importance to us. It is our POLICY to safeguard the confidentiality of information and respect the privacy of individuals. Please see below for information about how we manage PERSONAL DATA, and for information about your RIGHTS with respect to the processing of your PERSONAL DATA.

2. DEFINITIONS

The following terms are defined as follows:

• 2.1 “AML” means ANTI-MONEY LAUNDERING.
• 2.2 “Digital Asset” means any DIGITAL REPRESENTATION OF VALUE that may be traded via ATS Interface services, excluding non-fungible tokens.
• 2.3 “ATS”, “We”, “Us” refers collectively to ATS Interface.
• 2.4 “Personal data” refers to any information relating to an IDENTIFIED OR IDENTIFIABLE NATURAL PERSON, including names, identification numbers, location data, an online identifier, or to one or more factors specific to the physical, economic, cultural or social identity of a natural person.

3. YOUR DATA CONTROLLER

Our products and services are provided through local operating entities that are part of the ATS Interface group of companies. You are contracting with ATS Interface as specified in our T&C. The Platform you are contracting with is your DATA CONTROLLER, and is responsible for the collection, use, disclosure, retention and protection of your PERSONAL DATA in accordance with our GLOBAL PRIVACY STANDARDS.

4. HOW DO WE PROTECT PERSONAL DATA?

ATS Interface takes the SECURITY of PERSONAL DATA incredibly seriously.

5. INFORMATION WE MAY COLLECT ABOUT YOU

We obtain information about you in a number of ways through your use of our products and services, our websites, the account opening process, event subscribing, news and updates subscribing and from information provided in the course of on-going support service communications. In order to open an account with us, you must first complete and submit a “create account” form. By completing this form, you are requested to disclose PERSONAL DATA in order to enable ATS Interface to assess your application and comply with applicable laws and regulations.

The minimum information required for entering into a contract governing your use of our products and services, and for enabling us to comply with our STATUTORY OBLIGATIONS in respect of ANTI-MONEY LAUNDERING and crime and fraud prevention, is "Biographical information and contact information", "Verification information" (each defined below). Without this information, we cannot commence, or continue to perform our services or provide our products to you.

The information that we collect from you is as follows:

• Full name, contact details (e.g., email address, telephone number etc.), date of birth, place of birth, gender, citizenship (“Biographical information and contact information”);
• Trading account balances, trading activity (such as whether you participate in ATS Interface's VIP program, and custodial activity), your inquiries and our responses (“Trading information”);
• Verification information, which includes information necessary to verify your identity such as a passport, driver’s licence, selfie photos / videos, login credentials or Government-issued identity card, which may be processed using technologies that extract biometric data (“Verification information”);
• Other personal data or commercial and/or identification information – Information we, in our sole discretion, deem necessary to comply with our legal obligations under various AML obligations, “Other information”.

Information we collect about you automatically:

• Browser information – Information that is automatically collected via analytics systems providers from your browser, including your IP address, domain name, any external page that referred you to us, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform (“Browser information”);
• Log information – Information that is generated by your use of ATS Interfaces-branded websites, applications, services, or tools operated by ATS Interfaces that is automatically collected and stored in our log records. This may include device information such as device identifier, device operating system and model, device storage, Media Access Control (MAC) address and Subscriber Identity Module (SIM) information, signals relating to user behaviour and device interaction, marketing identifier, battery usage, location information, network address, system activity and any internal and external information related to pages that you visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website or App (including date and time, page response times, download errors, length of visits to certain pages, page interaction information such as scrolling, clicks, and mouse-overs, and methods used to browse away from the page) (“Log information”).

Information we receive about you from other sources.

We also receive information about you from third parties such as your payment providers, our service providers assisting with AML, fraud, and security compliance, and through publicly available sources. For example:

• Your business partners may provide us with your name and address, as well as financial information.
• Advertising networks, analytics providers and search information providers may provide us with anonymized or de-identified information about you, such as confirming how you found our website.
• Our service providers may provide us with information relating to fraud, security, sanctions and AML and other risks, for example, confirmation of identity attributes, and information about any attributes linked to such matters.
• Credit reference agencies may provide us with your PERSONAL DATA during the credit referencing process.
• We may read and store data that is written on a blockchain, other publicly available ledgers, or is otherwise in the public domain.

6. DISCLOSURE OF YOUR PERSONAL DATA

As part of processing your PERSONAL DATA for the purposes set out above, ATS Interface may disclose your PERSONAL DATA to any members of the ATS Interface company group, and to third parties. For example, ATS Interface may disclose your PERSONAL DATA to any of our service providers and business partners, for business or other legitimate purposes, such as specialist advisors who have been contracted to provide us with administrative, financial, legal, tax, compliance, insurance, IT, debt-recovery, analytics, research or other services.

If ATS Interface discloses your PERSONAL DATA to service providers and business partners, in order to perform the services requested by clients or to comply with our legal and regulatory obligations, such providers and partners may store your PERSONAL DATA within their own systems. We require them to protect the confidentiality of this PERSONAL DATA, and comply with all relevant privacy and data protection laws. ATS Interface may also disclose PERSONAL DATA when it is compelled by law, for example to a government agency as a result of a valid court order.

7. WHERE WE STORE YOUR PERSONAL DATA

Our operations are supported by a NETWORK of computers, servers, other infrastructure and information technology.

8. DATA RETENTION

When PERSONAL DATA is no longer necessary for the purposes for which it may lawfully be processed, we will remove any details that will identify you, or we will securely destroy the relevant records. We may need to maintain records for a significant period of time after you cease being our client for legal or regulatory reasons, for example, when we need to retain information to help manage a dispute or legal claim. Additionally, we are subject to certain ANTI-MONEY LAUNDERING laws which may require us to retain the following for a period (e.g., 5 years) after our business relationship with you has ended:

• A copy of the records we used in order to comply with our client due diligence obligations;
• Supporting evidence and records of transactions with you, and your relationship with us.

If you have opted out of receiving marketing communications, we will keep your information on our SUPPRESSION LIST to ensure that you do not receive these messages.

9. COOKIES

COOKIES are small text files that provide information regarding the device used by a visitor. Cookie information does not usually directly identify you, but it can give you a more PERSONALIZED WEB EXPERIENCE. Because we respect your RIGHT TO PRIVACY, you can choose not to allow some types of cookies although doing so may impact website functionality.

10. YOUR RIGHTS REGARDING YOUR PERSONAL DATA

The rights that are available to you in relation to the PERSONAL DATA we process are outlined below. You may request to exercise these rights subject to any limitations provided for under applicable data protection laws.

Access

You can ask us to confirm whether we are processing your PERSONAL DATA and, if so, what information we process. Should you wish to obtain a copy of that information, please contact

Rectification

It is important to us that your PERSONAL DATA is up to date. We will take all reasonable steps to make sure that your PERSONAL DATA remains accurate, complete and up-to-date. Please inform us if your PERSONAL DATA changes. If the PERSONAL DATA we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have disclosed your PERSONAL DATA to others, we will let them know about the rectification where possible. If you ask us, and if possible and lawful to do so, we will also inform you with whom we have shared your PERSONAL DATA.

Erasure

You can ask us to delete or remove your PERSONAL DATA in certain circumstances. Such requests may be subject to any retention limits we are required to comply with in accordance with applicable laws and regulations. If we have disclosed your PERSONAL DATA to others, we will let them know about the erasure request where possible. If you ask us, and if possible and lawful to do so, we will also inform you with whom we have shared your PERSONAL DATA.

Data portability

In certain circumstances you may have the right to obtain PERSONAL DATA you have provided to us, in a structured, commonly used and machine-readable format, and to re-use it elsewhere or ask us to transfer this to a third party of your choice, where technically feasible.

Objection

You can ask us to stop processing your PERSONAL DATA, and we will do so, if we are:

• Relying on our own or someone else’s legitimate interests to process your PERSONAL DATA except if we can demonstrate compelling legal grounds for the processing or for the establishment, exercise or defence of legal claims;
• Processing your PERSONAL DATA for direct marketing.

Complaints

You have the right to complain to a competent DATA PROTECTION AUTHORITY. Contact details are set out in Section 17 below. We ask that you first contact to give us an opportunity to address any concerns.

Withdraw consent

You have the right to withdraw CONSENT to processing based on consent at any time. Note this will not affect the lawfulness of processing based on consent prior to the withdrawal of consent or on grounds where consent is not required.

11. CONTACT INFORMATION

Any questions, complaints, comments and requests regarding this privacy notice are welcome and should be addressed to . You can also contact our DATA PROTECTION OFFICER at .

12. DATA PROTECTION AUTHORITIES

If you are not satisfied with our response to your complaint, you have the right to submit a complaint to a competent DATA PROTECTION AUTHORITY.