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Privacy Notice

1. Introduction

ISEC Wealth Management Limited (hereinafter the “Company”), is committed to protect your privacy and handling your data through a transparent manner. The Company understands the importance of maintaining the confidentiality and privacy of your personal data. By entrusting us with your information, we would like to assure you of our commitment to keep such information private. We have taken measurable steps to protect the confidentiality, security, and integrity of your Information.

In accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation or “GDPR”), where you are a natural person, the Company acts as a controller of your personal data in relation to the processing activities described in this Privacy Notice. For the purposes of this Privacy Notice:

i) Personal Data shall mean any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

ii) Controller shall mean the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

iii) Processor shall mean a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

2. Privacy Notice

This Privacy notice aims to provide you with an overview of how the Company collects and processes your personal data and informs you about your rights under the local data protection law and the EU General Data Protection Regulation (hereinafter the “GDPR”). This statement is directed to natural persons, who are either current or potential clients of the Company. Furthermore, this statement is directed to natural persons, who had a business relationship with the Company in the past. Further to the above, this statement is providing you with information on the Circumstances that the Company may share your personal information with any third party related to the Company, such as payment service providers.

3. Who We Are

The Company is an authorised firm, established in Cyprus, with registration number ΗΕ 360500. The Company is registered and licensed by the Cyprus Securities and Exchange Commission (hereinafter the “CySEC”) with license number 356/18. If you have any questions or want more details about how the Company uses your personal information, you can contact our Data Protection team at [email protected]

4. Collection of Information

As part of the Company’s client account opening procedures and ongoing regulatory obligations, the Company is required to collect and process certain personal data in accordance with the applicable legal and regulatory framework. This includes, where applicable, obligations arising under the Prevention and Suppression of Money Laundering and Terrorist Financing Law of 2007, as amended, and the applicable CySEC Directive for the Prevention and Suppression of Money Laundering and Terrorist Financing, including requirements relating to customer due diligence and the establishment and ongoing monitoring of the Client’s economic profile. The Company also collects and processes personal data as necessary to comply with its obligations under the Investment Services and Activities and Regulated Markets Law of 2017, as amended, Commission Delegated Regulation (EU) 2017/565, and other applicable regulatory requirements, including requirements relating to suitability and appropriateness assessments, record-keeping, the recording of communications and transactions, and applicable tax reporting obligations, including FATCA and CRS.

The Company, based on the points above, is obliged to request, collect and maintain for at least five (5) years the following information:

i) Name and Surname

ii) Date of Birth

iii) Place of Birth

iv) Nationality

v) Copy of the Passport and/or of the Identity Card

vi) Utility bill (including the full address of the client)

vii) Tax Identification Number

viii) Tax Residence

ix) Telephone number

x) Email

xi) Employer’s name

xii) Profession

xiii) Industry of Employment

xiv) Gross Annual Income

xv) Net Worth

xvi) Anticipated Turnover

xvii) Bank Account Details

The Company may collect the above information directly from you (during the account opening procedure) and/or from other persons, including for example, credit reference agencies, fraud prevention agencies, banks, other financial institutions, third party authentication service providers (the Company is using World Check and RDC for authentication purposes and background purposes) and also from public registers. The Company may also collect the information about you based on your use of our website(s), such as pages visited, frequency, duration of visit and trading activities. The Company also keeps records of your portfolio, including a record of:

a) Products traded on your portfolio and their performance;

b) Historical data about the trades and investments including the amount invested;

c) Historical data about your payment activities and your withdrawal activities.

Further to the above, the Company may also request further information to improve its service to you (Existing or Potential Clients) or our activities (if you are our Provider for Trading Data) under our relevant Agreement, as the case may be, or comply with Applicable Regulations.

The Company records any communications, such as electronic, telephone, in person or otherwise, that we may have with you in relation to the services that were provided by the Company to you and the relationship with you. The said recordings will be the Company’s sole property and will constitute evidence of the communications between the Company and yourself.

5. To Whom the Company May Disclose Your Information

As part of using your personal information for the purposes mentioned above, we may disclose your information to the following parties:

a) Service providers and specialist advisers, who have been contracted to provide us with IT, financial, regulatory, compliance, accounting and/or other services.

b) Tied Agents, with whom the Company has established relationships and who are exclusively working for the Company.

c) Regulatory Authorities.

d) Anyone authorised by you.

e) Relevant authorities to investigate or prevent fraud, money laundering or other illegal activity.

f) Trade Repository or similar.

g) The Company’s employees to exercise their duties in accordance with the Agreement between the Company and yourself. The Company requires from organisations outside the Company, who handle or obtain personal information, to acknowledge the confidentiality of this information, undertake to respect any individual’s right to privacy and comply with all the relevant data protection laws and this privacy notice.

6. Use of the Information

The Company will collect, use, store and otherwise process your personal data in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation or “GDPR”), the Cyprus Law providing for the protection of natural persons with regard to the processing of personal data and for the free movement of such data, Law 125(I)/2018, as amended, and other applicable data protection legislation. Personal data will be collected for specified, explicit and legitimate purposes and will not be further processed in a manner incompatible with those purposes. The Company will collect and process personal data that is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.

Where the Company transfers personal data outside the European Economic Area (“EEA”), such transfers will be carried out in accordance with the applicable requirements of the GDPR. Depending on the circumstances, the Company may rely on an adequacy decision adopted by the European Commission or implement appropriate safeguards, such as the European Commission’s Standard Contractual Clauses, or another transfer mechanism permitted under applicable data protection legislation.

7. Legal Bases for Processing Your Personal Data

The Company processes your personal data only where it has a lawful basis for doing so under applicable data protection legislation. Depending on the purpose and circumstances of the processing, the Company may process your personal data on one or more of the following legal bases:

a) Performance of a contract: where processing is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract.

b) Compliance with a legal obligation: where processing is necessary for the Company to comply with its legal and regulatory obligations, including obligations relating to client identification and verification, anti-money laundering and counter-terrorist financing, suitability and appropriateness assessments, record-keeping, transaction and communications recording, regulatory reporting and applicable tax reporting requirements.

c) Legitimate interests: where processing is necessary for the purposes of the legitimate interests pursued by the Company or a third party, provided that such interests are not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.

d) Consent: where the Company relies on your consent for a specific processing activity. Where consent is relied upon, it will be requested in a manner that is freely given, specific, informed and unambiguous. You may withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

e) Other lawful bases: where applicable, the Company may process personal data where this is necessary to protect the vital interests of an individual or for the performance of a task carried out in the public interest, in accordance with applicable law.

The lawful basis relied upon will depend on the specific purpose for which the personal data is processed. Where the Company is required by law or regulation to collect and process certain personal data, withdrawal or absence of consent does not affect processing carried out on another applicable lawful basis.

8. For How Long We Keep Your Personal Data

The Company shall keep your personal data for as long as the company has business relationship with you (physical person). Once the business relationship has been ended, we may keep your data for up to five (5) years in accordance with the Laws governing the Company. The Company may keep your personal data for longer than five (5) years for legal, regulatory and/or any other obligatory reason.

In case you will not activate your investment account, all of your personal data will be deleted in accordance with our internal procedures after 6 (six) months of non-activity.

Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

9. Management of Your Personal Information and Safeguard Measures

The Company has taken all the appropriate organisational measures to ensure that your personal data are secured. Moreover, the Company has established an internal educational training for its employees so as to mitigate any risks that may affect your data. The employees that are processing your data are being trained to respect the confidentiality of customer information and the privacy of individuals. We consider breaches of your privacy as top priority and the Company will enhance its internal procedures to prevent any such event.

The Company has implemented procedures in respect of safeguarding your data. Access to your information is only given to the employees and/or Tied Agents that need to have access to it in order to enable the continuity of the agreement between you and the Company.

Furthermore, we hold personal information in a combination of secure computer storage, secure servers and from time to time if it is deemed necessary we will store them in paper-based files. The Company has taken all the necessary steps to protect the personal information that it holds from misuse, loss, unauthorized access, modification or disclosure.

While we will use all reasonable efforts to safeguard your information, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data transferred from you, or to you via the internet.

10. Change of Information

You may inform the Company at any time that your information has changed or that you wish the Company to delete information we hold about you by emailing us at [email protected] . We will change or delete your information in accordance to your instructions, except to the extent that we are required to hold your information for regulatory or legal purposes, to provide you with the Services you have requested or to maintain adequate business records.

11. Right of Access

As a natural person you have the right to obtain a copy of any personal information which we hold about you and to advise us of any perceived inaccuracy. Additionally, you may also request the reasoning of holding such information.

To make a request, please contact us, verifying your identity and specifying what information you require. You may contact us via e-mail at [email protected]

12. Questions

If you have any questions regarding this Privacy Notice, wish to access or change your Information, have a complaint, or if you have any questions about the security on our Website, you may email us at [email protected].

Furthermore, in case you are not happy with the quality of Services we have provided you with regards to the personal data processing, , as a natural person, you have the right to lodge a complaint with our supervisory authority, which is the Commissioner for Personal Data Protection in the Republic of Cyprus.

13. Update of This Notice

This Privacy Notice may be updated from time to time. If we make any material changes that affect the way we process your personal data, we will inform you in advance by email or through a prominent notice on our website or through the client area. We encourage you to review this Notice periodically to stay informed about how we protect your information.

RISK WARNING

Investing in financial instruments involves a high degree of risk and may not be suitable for all investors. Trading in financial instruments can result in both an increase and decrease in capital. Please refer to our Risk Disclosure available in our web site for further information.

CFDs are complex instruments and come with a high risk of losing money rapidly due to leverage. The vast majority of retail investor accounts lose money when trading CFDs. You should consider whether you understand how CFDs work and whether you can afford to take the high risk of losing your money.

CONTRACT TERMS

For more information about the company's policies when using this website and the contract terms that are used when opening an account with ISEC, please go to CONTRACT TERMS .

Company information, Terms and conditions agreement, Portfolio management addendum, Custody addendum, Risk disclosure and warning, Conflict of interest, Order execution policy, Investor compensation fund, Client categorisation policy, Privacy policy, Commission and charges schedule, Complaints procedure for clients, Terms of use of website

RISK WARNING: Investing in financial instruments involves a high degree of risk and may not be suitable for all investors.

CFDs are complex instruments and come with a high risk of losing money rapidly due to leverage. The vast majority of retail investor accounts lose money when trading CFDs. You should consider whether you understand how CFDs work and whether you can afford to take the high risk of losing your money.

RISK WARNING: Investing in financial instruments involves a high degree of risk and may not be suitable for all investors.

CFDs are complex instruments and come with a high risk of losing money rapidly due to leverage. The vast majority of retail investor accounts lose money when trading CFDs. You should consider whether you understand how CFDs work and whether you can afford to take the high risk of losing your money.