THE PRIVACY OF OUR CLIENTS IS OUR TOP PRIORITY

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THE PRIVACY OF OUR CLIENTS IS OUR TOP PRIORITY

XSpot Wealth (EU) Ltd. with head office address at 201 office, 3rd floor, 68 Spyrou Kyprianou, Kato Polemedia, 4154 Limassol, Cyprus Tel: +35725 571044 Co.Reg. HE320496, is a Cypriot Investment Firm incorporated and registered under the laws of the Republic of Cyprus, which is authorized and regulated by the Cyprus Securities and Exchange Commission (hereafter the “CySEC”) under license no. 235/14 (hereafter the “Company”).

XSpot Wealth (EU) Ltd. and its related entities (hereafter “the Company”), are responsible for the protection of the privacy and the safeguarding of clients’ personal and financial information. 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

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 gathers information from (prospective) clients and may, 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 to provide its services effectively. 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.

Usage of personal information

The Company will use, store, process and handle your Data in accordance with the Processing of Personal Data (Protection of the Individual) Law of 2001, and the General Data Protection Regulation (GDPR) (EU) 2016/679 of 2016, as amended or replaced from time to time. 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. If the clients do not want to receive information of this nature for any reason, they can contact the Company at the following website: https://xspotwealth.com/

Protection of personal information

Any personal information provided by the client to the Company will be treated as confidential and shared only within the Company and will not be disclosed to any third party except in the circumstances mentioned in the below sections.

Affiliates and Partners

The Company may share information with affiliates or any other company in the same group of the Company in the event such information is reasonably required to provide the products or services to its clients. The Company may share information with partners, affiliates and associates 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.

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Non-affiliated third parties

The Company does not sell, license, lease or otherwise disclose clients’ personal information to third parties, except as described below:

Client information is disclosed in compliance with the common reporting standard (CRS) for the automatic exchange of financial account information developed by the Global Forum of the Organization for Economic CoOperation and Development (OECD); in the cases where your tax residence is located outside Cyprus, the Company may be legally obliged to pass on the information and other financial information with respect to your financial accounts to Cyprus tax authorities and they may exchange this information with tax authorities of another jurisdiction or jurisdictions pursuant to intergovernmental agreements to exchange financial account information. Under such circumstances, the Company shall expressly inform the third party regarding the confidential nature of the information. 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. In cases where clients have been introduced by a Business Introducer, such Business Introducer may have access to clients’ information. Hence, clients hereby consent to the sharing of information with such Business Introducer

Recording of Telephone Conversations and Electronic Communications

Telephone conversations and electronic communications between the client and the Company will be recorded and kept by the Company for a period of up to seven years and recordings will be the sole property of the Company. The client accepts such recordings as conclusive evidence of conversations so recorded. Such recordings shall be provided to the client upon request

Contact Clients

From time to time the Company may contact clients whether by phone or email for offering them further information about the Company’s contract for differences trading. In addition, the Company may, on occasion, seek to contact clients, whether by phone or by email, for informing them of unique promotional offerings provided by the Company for the client. Clients consent to the receipt of such contact when they consent to our terms and conditions of use when registering with the Company. Any person wishing to opt out of further contact with the Company at any time whatsoever is entitled to do so, simply by contacting the Company whether by phone (00357-25571044) or email (at info@xspotwealth.com ) and requesting that no further contact on behalf of the Company be made.

Clients’ rights of access to their personal information

Clients have the right to access all the personal information that the Company holds about them under European data protection legislation. Clients can also require from the Company to correct or delete any inaccurate personal information.

Clients’ right to erase their personal information

Clients have the right to request the erasing of all their personal data from the Company, however the Company is permitted to erase Clients’ data if it is held under the legal lawful bases. Furthermore, the Client can object to the processing of any data where the lawful bases is ‘Consent’. Hence the Client can object to the Company’s use of Clients’ personal information for direct marketing purposes at any time and the Client may have the right to object to the Company’s processing of some or all Clients’ personal information. If the Clients wish to exercise any of these rights, they can contact the Company at backoffice@xspotwealth.com

Clients’ right subject to access

Clients can request to see a copy of the personal data that the Company holds for them. If the Clients wish to see this data, then they must submit a written request (post or email) requesting this information to backoffice@xspotwealth.com The Company may charge a reasonable fee to comply with this request when it is manifestly unfounded, excessive or repetitive.

Clients’ right to complaint

The Company commits to investigate and resolve complaints about the collection or use of Clients’ personal information. To make a complaint, Clients can contact the Company at complaints@xspotwealth.com. To help the Company address the issue effectively, Clients must provide the following: Their data privacy complaint (please provide as much detail as possible including your understanding of the data privacy infringement issue(s);

Their full name and how the Company can contact them; and Any previous correspondence on this specific data privacy issue. If the Clients feel that the Company has not met its obligations in relation to Clients’ data issue, Clients have the right to make a complaint to the supervisory authority at commissioner@dataprotection.gov.cy.

Clients’ right to complaint

The Company commits to investigate and resolve complaints about the collection or use of Clients’ personal information. To make a complaint, Clients can contact the Company at complaints@xspotwealth.com. To help the Company address the issue effectively, Clients must provide the following: Their data privacy complaint (please provide as much detail as possible including your understanding of the data privacy infringement issue(s);

Their full name and how the Company can contact them; and Any previous correspondence on this specific data privacy issue. If the Clients feel that the Company has not met its obligations in relation to Clients’ data issue, Clients have the right to make a complaint to the supervisory authority at commissioner@dataprotection.gov.cy.

Restriction of responsibility

The Company is not responsible for the privacy policies or the content of sites to which www.xspotwealth.com links and has no control of the use or protection of information provided by the clients or collected by those v.sites. XSpot Wealth (EU) Ltd. shall not be liable for information provided by the client to linked websites. Please note that such information is recorded by a third party and will be governed by the privacy policy of that third party.

Use of "COOKIES"

The Company uses cookies to secure clients’ trading activities and to enhance the performance of the web site www.xspotwealth.com. Cookies used by the Company do not contain personal information or other sensitive information. The Company may share web site 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 web site www.xspotwealth.com, the Company may use third parties to track and analyse 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 information.

Mailing list

When the Client opens a trading account with the Company he agrees to joining the Company’s mailing list to receive company news, product updates, and analysis & research updates. If the Client wishes to unsubscribe from the mailing list, he must inform the Company in writing by email at info@xspotwealth.com

Record Keeping

Under Applicable Regulations, the Company will keep records containing Client personal data, trading information, Client’s Trading Account(s) opening documents, communications and anything else which relates to the Client for at least five (5) years after termination of the Agreement.

Privacy Policy Updates

The Company may update this Privacy Policy from time to time. If the Company materially changes this Policy including how it collects, processes or uses clients’ personal information, the revised Privacy Policy will be uploaded in the Company’s website. In this respect, the Company shall send any new version of the present Policy to its existing clients for their further acceptance, every time a change is affected.

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