FINOTIVE

PRIVACY & COOKIES POLICY

May 2026

1. Introduction

Finotive is the Brand name of the below entities which operate the respective domains through which Services are provided to Clients:

Finotive Markets LLC that operates finotivemarkets.com holds registration in Saint Vincent and the Grenadines under number 2152 LLC 2022 with its registered office address at Suite 305, Griffith Corporate Centre, Beachmont P.O.Box 1510, Kingstown, St. Vincent and the Grenadines.

Which are collectively being hereinafter referred to as the ‘Finotive’.

2. Purpose

This Privacy and Cookies Policy (the ‘Policy’) defines requirements to help ensure compliance with laws and regulations applicable to the Company in the process of collection, storage, use, transmission, disclosure to third parties and retention of Personal and special categories of personal data (also referred to as personal and sensitive personal information respectively in this policy).

3. Scope

This policy is applicable to all Finotive’s past, present or potential employees, contractors, vendors, interns, customers, and business partners who may receive personal information from Finotive, have access to personal information collected or processed by or on behalf of Finotive, or who provide information to the Company.

This policy covers the treatment of personal information gathered and used by Finotive for lawful business purposes. This policy also covers the personal information we share with authorized Third Parties or that Third Parties share with us.

4. GDPR Compliance

Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “GDPR”) shall apply only if our services are directed to or accessed by users located in the European Union (EU) or European Economic Area (EEA).

When applicable, we process personal data under the following lawful bases:

• Consent (Article 6(1)(a) GDPR) – for email marketing or cookie tracking when consent is provided.
• Contract (Article 6(1)(b) GDPR) – to perform our obligations when you use our services.
• Legitimate Interest (Article 6(1)(f) GDPR) – for fraud prevention, business analytics, and improving our services.

Data subjects located in the EU/EEA have the right to access, rectify, erase, restrict, object to, or port their data. Requests can be submitted to Support teams of Finotive.

Cookies and Tracking Technologies

Our Site uses cookies and similar tracking technologies to enhance user experience, analyze traffic, and personalize content. Cookies are small files stored on your device. You can control or disable cookies through your browser settings. If you reject cookies, some parts of the Site may not function properly.

Types of cookies we may use include:

• Essential cookies: Required for website functionality.
• Analytics cookies: To understand how users interact with the Site.
• Preference cookies: To remember your settings.
• Marketing cookies: Used for advertising and remarketing (only with consent if GDPR applies).

Data Retention

Personal Data will be retained for as long as necessary to fulfill the purposes outlined in this Policy, or as required by law. Account-related data may be kept for at least five years following account closure to comply with recordkeeping and anti-money laundering obligations.

Security

We take reasonable technical and organizational measures to protect personal data. However, no transmission over the internet is completely secure, and we cannot guarantee absolute protection.

International Data Transfers

If GDPR applies, and personal data of EU/EEA users is transferred outside the EEA, we ensure adequate safeguards are in place, such as Standard Contractual Clauses or equivalent mechanisms.

Data Processing Agreement (DPA)

Data may be processed by third-party service providers acting on our behalf under Data Processing Agreements.

5. Information Collection and Use

The Company collects the necessary information required for the Company to open, transact in and safeguard its client’s accounts. Finotive ensures that it only collects the necessary information required. In relation to the processing activities which the Client’s personal data undergoes, the Company acts as the personal data controller of the Client’s personal data collected.

To provide its services effectively and in accordance with the relevant laws and regulations, the Company gathers two types of data and information from Clients and other stakeholder (e.g., from banks and/or payment providers, and/or other sources) to construct the respective profiles based on the Client’s requirements and preferences namely the Non-personal Information and Personal Information collectively referred to as “Your Data”.

Non-personal Information

It is un-identified and non-identifiable information, which may be made available or gathered via your use of the Site, even if you do not participate or register to the Company’s Site. We are not aware of the identity of the Individual from which the Non-personal Information was collected.

Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).

Personal Information

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). Such information includes:

• Registration information: When you open an account, you will be asked to provide us certain details such as: full name, e-mail address date of birth, physical address, telephone number, and other information, as further described in Client Agreement/Terms and Conditions/registration form.
• Device Information: We may also collect Personal Information from your device. Such information includes geolocation data, IP addresses, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.
• Payment Information: To execute withdrawals and for anti-money laundering purposes, you may be required to share personal information within the site or with our trusted payment processor. Such personal information may include your name, billing address, identity number, financial information (e.g. your credit card number, bank account, etc.) and any other information that is required to perform transactions.

Based on the aforementioned, the Company collects information which is required to communicate with and identify its clients. In addition, certain demographic information, including birth date, education, occupation, etc. maybe also collected from the Company’s Clients along with information related to trading so that the Company to be able to assess trading related details which are deemed to be necessary. Examples include:

• Application information that includes personal information provided by the Client in the Company’s application form. The Client’s name, address, date of birth, email address, income and income source is asked. This information is also used by the Company in order to communicate with the Client.
• Transaction information that includes information about the anticipated volume and value of the Client’s transaction with the Company. The Client’s economic profile is also construed based on this information.
• Verification information that includes the Client’s identity card, passport or driver’s license.

The provision of data is required from you to enable us to provide our services. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.

In the course of your registration as a client, signing up with Finotive or filling in any form on our Website, subscribing to our services, news or offers, marketing communications or posting material, the following information about you (“Your Data”) will be collected and stored for administrative, service related and/or legal purposes.

We will limit the collection of personal information to what is necessary to administer our business and carry out activities in an effort to provide you with superior service, Information that you provide to us directly:

• Personal information, such as names, addresses, personal registration number, national identification number, passport number and email addresses etc. (“Personal Information”), and
• Financial Information, including but not limited to, trading experience and employment information for appropriateness assessment will also be collected.

However, the meaning of data provided to Finotive is not limited to this. It is also

personal data resulting from observation of your activities (i.e., where using a device or service).

This may include:

• History of website usage or search activities, details of your visits to our Website including, communication data;
• Traffic and location data;
• Website traffic pattern information, including IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This kind of information is only used in masked or aggregated form, which means that the individual user will not be recognizable. These data do not identify any individual.
• Communication between you and Finotive via Live Chat, email, or telephone call.

Specifically, please refer to the table below for the type of date collected and the purpose of the relevant collection:

5.1

Personal Information includes Full Name, date of birth, address, citizenship, ID or passport number - To verify your identity using our verification processes to prevent fraud, chargebacks, or abuse of our services..

5.2

Contact Information including phone number and email address - In order to send you correspondence in relation to the services provided..

5.3

Financial sanctions and credit header information - to prevent fraud, chargebacks, or abuse of our services IP address - When you visit our website, navigate through the pages or fill in any forms, we may collect your unique device number or IP address in order to set up your profile.

5.4

Proof of identification & proof of address – to identity verification to prevent fraud, chargebacks, or abuse of our services.

6. Log Data

Like many site operators, we collect information that your browser sends whenever you visit our Site (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics.

In addition, we may use third party services such as Google Analytics that collect, monitor and analyze.

7. Retention of Personal Data

We will retain your personal information for as long as necessary to provide our services, and to comply with our legal obligations, resolve disputes, and enforce our policies. 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. Under applicable regulations, we will keep records containing Client personal data, account opening documents, communications and anything else as required by applicable laws and regulations.

You can close your account any time, but for audit trail purposes, Finotive shall hold personal data for a period of at least five (5) years after closing the account in order for us to comply with our record keeping obligations under the Money Laundering Regulations 2017.

At the end of that period, we will delete all personal data relating to you, unless a legal requirement requires them to keep the data for a prolonged period of time, or Data Subject has expressly consented to their data being held for an extended period of time.

8. Security of Personal Data

The Company takes reasonable technical and organizational measures to prevent the loss, misuse or alteration of its clients’ personal information. The Company stores all the personal information which is provided by the Clients on its secure (password- and firewall-protected) servers.The Clients are responsible for keeping the password they use for accessing our website confidential; the Company will not ask the clients for their passwords (except when they log in to the Company’s website).The personal information which is provided by the clients to the Company is treated as confidential and shared only within the Company, its affiliates and service providers based on the service involved and are not disclosed to any third party except under any regulatory or legal proceedings. In case where such disclosure is required to be made by law or any regulatory authority, it will be made on a ‘need-to-know’ basis, unless otherwise instructed by the regulatory authority. In such cases, the Company shall duly inform the third party regarding the confidential nature of the information.

9. Communications

Your Data and especially the e-mail address may be also used by Finotive in relation to promotion of its products and services (including any marketing campaigns related to these products or services).

10. How to opt out?

If you do not wish to receive such marketing materials and marketing communications, you can opt-out at any time by clicking on “unsubscribe” or by sending us an email stating so.

You can submit an official request /complaint providing the following details:

10.1

Personal Details:

• Name and surname;
• Trading account number;
• Email address;

10.2

Specific Details of the Request

10.3

Representatives

Only complete if you wish to be represented by a third party. Please note that you will be required to provide the Power of Attorney authorizing the relevant third party to act on your behalf.

• Name of the representative;
• Your relationship with the representative;
• Email address;
• Contact number;
• Postal address.

11. Corporate transaction

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

12. Minors

We forbid users under the age of 18 to register or trade using our services. If we become aware that a user under the age of 18 has shared any information, we will discard such information. If have any reason to believe that a child under 18 has shared any information with us, please contact us.

13. Limitation of Responsibility

The Company is not responsible for the privacy policies or the content of sites to which Finotive websites may link and has no control of the use or protection of information provided by the clients or collected by those sites. Whenever a client elects to link to a co-branded web site or to a linked web site, the client may be asked to provide registration or other personal information. Please note that such information is recorded by a third party and will be governed by the privacy policy of that third party.

14. Cookies

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive.

Like many sites, we use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.

15. Changes to the Policy

This Privacy Policy is effective as of March 2025 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Privacy Policy at any time, and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

16. Contact Us

If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us with, or by placing a prominent notice on our website.

If you have any questions about this Privacy Policy, please contact one of our Support Team.