Privacy Policy and Data Collection Policy

1. Who We Are and What This Policy Covers

1.1 This Privacy Policy and Data Collection Policy (the "Policy") is issued by EREGION INFORMATION TECHNOLOGY - FZCO, a free zone company incorporated in the United Arab Emirates, of Dubai, United Arab Emirates ("Eregion", "we", "us", "our").

1.2 This Policy describes how we collect, use, store, disclose and otherwise process data — including personal data — relating to: (a) visitors to our website and any applications, portals or online tools we operate (together, the "Site"); (b) persons who apply to become clients or partners; and (c) our clients and partners and, where they are entities, their principals, officers and personnel (together, "you", "your"). Our clients and partners are also referred to as "Partners".

1.3 In this Policy: "Services" means the operational, informational and administrative support services we provide to Partners, as described in our Client Services Agreement (the "Services Agreement"); and "Counterparty" means any proprietary trading firm, simulated or funded trading service provider, evaluation platform, signal distribution platform or similar third-party service with which a Partner holds, seeks or operates an account or relationship.

1.4 By accessing or using the Site, applying to become a Partner, providing data to us, or using the Services, you acknowledge this Policy and, to the fullest extent permitted by applicable law, consent to the collection, use, processing, disclosure and cross-border transfer of your data as described in it. For Partners, this Policy forms part of the arrangements referred to in the Services Agreement and should be read together with it.

1.5 If you do not agree with this Policy, do not use the Site or the Services or provide data to us. Continued use following any update to this Policy constitutes acceptance of the updated Policy.

2. Data We Collect

2.1 We collect data in three ways: directly from you, automatically through the Site, and from third parties in the course of providing the Services.

2.2 Data you provide directly may include:

1. identity data: full name, date of birth, gender, nationality, country of residence, residential address;
2. identity documents and verification data: copies of passports, photo identification, national identity cards, driving licences, visas and residence permits; proof-of-address documents; photographs, verification selfies, video and liveness-check data; and any other documents requested for onboarding or Counterparty verification;
3. contact data: email addresses, telephone numbers, messaging handles and social media identifiers;
4. financial and payment data: bank account details, card details (processed via payment providers), digital wallet addresses, transaction records, billing history and tax identifiers;
5. professional and business data: trading experience, platforms used, turnover and performance information, business structures and related interests;
6. trading and account data: Counterparty account identifiers, account status, trade reports, positions, strategies discussed with us, performance metrics and payout information;
7. application data: any information submitted through application, contact or enquiry forms on the Site; and
8. communications: correspondence, call and meeting records, support requests and feedback.

2.3 Data we collect automatically through the Site may include: IP address, device identifiers, browser type and settings, operating system, referral source, pages viewed, time spent, clickstream data, approximate location derived from IP address, and data collected through cookies, pixels, local storage and similar technologies (see clause 8).

2.4 Data we receive from third parties may include: information from Counterparties about your accounts, verification status, activity and payouts; information from our remote assistants, subcontractors and service providers generated in delivering the Services; information from payment providers; information from identity-verification, data hosting and credential-management providers; and publicly available information.

2.5 The Services cannot be provided without the collection and processing of the data described in this Policy. Identity documents and similar data may be required for, among other things, Counterparty onboarding, verification and compliance processes.

3. How We Use Data

3.1 We may collect, use, store, analyse, combine and otherwise process your data for the following purposes:

1. operating, securing and improving the Site, and responding to enquiries and applications;
2. assessing applications and onboarding Partners;
3. providing, administering, personalising and improving the Services;
4. establishing, verifying, maintaining, operating and managing Partners' accounts and relationships with Counterparties, including completing Counterparty onboarding, verification and compliance processes on the Partner's behalf or with the Partner's assistance;
5. engaging and coordinating remote assistants, subcontractors and service providers in the delivery of the Services;
6. billing, payment processing and collection, including revenue-participation arrangements where agreed;
7. monitoring Counterparty risk and compiling research, analytics, datasets and aggregated or de-identified insights;
8. marketing and communications, including service notices and information about services, features and offers that may be of interest (you may opt out of marketing communications at any time);
9. detecting, investigating and preventing fraud, misuse and security incidents;
10. complying with applicable law, regulation and lawful requests of courts, regulators and authorities;
11. establishing, exercising or defending legal claims and enforcing our agreements; and
12. any purpose reasonably related to the above, or otherwise notified to you or consented to by you.

4. Who We Share Data With

4.1 Disclosure to Counterparties. By providing data to us or using the Services, each Partner expressly consents to, and authorises, our disclosure of their data — including personal data and copies of identity documents — to each and any Counterparty, for the purposes described in clause 3, including for the establishment, verification, maintenance, operation and management of the Partner's accounts and relationships with that Counterparty.

4.2 We may also disclose your data, for the purposes described in clause 3, to:

1. our affiliates, personnel, remote assistants, subcontractors and service providers engaged in operating the Site or delivering the Services, wherever located;
2. third-party data hosting, identity-verification, credential-management and technology providers referred or engaged in connection with the Services, who process data under their own terms;
3. payment processors, banks, card schemes, digital-asset service providers and other financial infrastructure providers used to receive or make payments;
4. analytics, marketing and communications providers supporting the Site and our communications;
5. professional advisers (including legal, accounting and audit) under duties of confidence;
6. courts, arbitral tribunals, regulators, law enforcement and other authorities where required or permitted by law, or where we consider disclosure reasonably necessary to protect our rights, our other Partners or the public;
7. a purchaser or prospective purchaser, investor or financier in connection with any sale, financing, reorganisation or transfer of all or part of our business, subject to appropriate confidentiality; and
8. any other person with your consent or at your direction.

4.3 Independent recipients. Counterparties, payment providers and other independent recipients handle data under their own terms and privacy practices, for which we are not responsible. You should review the applicable Counterparty's privacy terms before establishing or operating an account with it.

4.4 Aggregated and de-identified data. We may create, use and disclose aggregated, anonymised or de-identified data derived from your data — including market, performance and Counterparty-risk analytics — for any lawful purpose, provided it does not identify you.

5. International Transfers

5.1 We operate internationally. The recipients described in clause 4 — including Counterparties, remote assistants and service providers — are located in various countries. By providing data to us or using the Services, you expressly consent to the transfer of your data to, and its storage and processing in, countries outside your country of residence, including countries that may not provide an equivalent standard of data protection. Where required by applicable law, we will implement appropriate safeguards for such transfers.

6. Data You Provide About Others

6.1 If you provide us with data relating to any other natural person (including principals, personnel, associates or contacts), you warrant that you have that person's authority and any consents necessary for its provision to us and its use and disclosure as described in this Policy, and that you have made this Policy available to them.

6.2 You must ensure that data you provide is accurate and current, and promptly notify us of material changes.

7. Security and Retention

7.1 We take reasonable technical and organisational measures, appropriate to the nature of the data, to protect data in our possession or control against unauthorised access, loss or misuse. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Certain data services are provided by third-party providers under their own terms.

7.2 We retain data for as long as reasonably required for the purposes described in clause 3, including for the duration of any Partner relationship and afterwards as needed for record-keeping, legal, regulatory, accounting, tax, dispute-resolution and enforcement purposes, after which it will be deleted or de-identified.

8. Cookies and Similar Technologies

8.1 The Site uses cookies, pixels, local storage and similar technologies to operate and secure the Site, remember preferences, measure and analyse usage, and support marketing. These may be set by us or by third-party providers (such as analytics and advertising services), who may combine the data with other information they hold.

8.2 You can manage cookies through your browser settings and, where offered, through any cookie preferences tool on the Site. Disabling cookies may affect Site functionality.

9. Marketing Communications

9.1 We may send you marketing and promotional communications by email or other channels. You may opt out at any time by using the unsubscribe mechanism in the communication or by contacting us at the address in clause 12. Service and transactional communications are not affected by a marketing opt-out.

10. Your Rights

10.1 Subject to applicable law, you may request access to, or correction or deletion of, personal data we hold about you, object to or request restriction of certain processing, request portability of certain data, and withdraw any consent you have given, by written request to the contact address in clause 12. We will respond within a reasonable period and may verify your identity before acting on a request.

10.2 Withdrawal of consent takes effect prospectively only: it does not affect processing or disclosures carried out before withdrawal, and does not require us or any recipient to retrieve data already disclosed. Because the disclosures described in clause 4 are integral to the Services, withdrawing consent or objecting to processing we reasonably consider necessary may mean we are unable to provide some or all of the Services, and for Partners the suspension and termination provisions of the Services Agreement will apply.

10.3 Nothing in this Policy excludes rights you have under applicable data protection law that cannot be excluded or varied, and this Policy is to be read subject to any such law. Depending on your location, you may also have the right to lodge a complaint with a data protection authority.

10.4 This Policy is not intended for, and the Site and Services are not directed at, persons under 18 years of age, and we do not knowingly collect their data.

11. Changes to This Policy

11.1 We may amend this Policy from time to time by posting the updated version on the Site (and, for Partners, by notice under the Services Agreement). The updated Policy applies from the date it is posted or notified. Your continued use of the Site or the Services after that date constitutes acceptance of the updated Policy.

12. Contact, Governing Law and Disputes

12.1 Questions, requests and complaints regarding this Policy or our handling of data should be directed to: partners@eregioninfo.tech / Dubai, United Arab Emirates.

12.2 This Policy and any non-contractual obligations arising out of or in connection with it are governed by the laws of the Dubai International Financial Centre (DIFC). Any dispute arising out of or in connection with this Policy shall be resolved in accordance with the dispute resolution provisions of the Services Agreement (arbitration administered by the Dubai International Arbitration Centre, seat DIFC, one arbitrator, English language) or, for persons who are not Partners, by arbitration on the same terms.