Privacy Policy

Introduction

Your privacy is very important to Score Capital Markets (ScoreCM). We are committed to protecting and respecting your personal data. This Privacy Policy describes what types of personal data we collect about you when you choose to use our services, how we will use your personal data, when and with whom we share it, and how we will keep it safe. It also details your rights in respect of our processing of your personal information and how you may exercise them. Please take the time to read and understand this policy.

We may make changes to this Privacy Policy from time to time and it is important that you check this Policy for any updates. Any personal information we hold will be governed by the current privacy policy in effect at the given time. If we make changes that we consider to be important, we will communicate them to you.

Please note that this Privacy Policy is addressed to our customers and potential customers.

Who we are

This Privacy Policy applies to the processing activities of the following data controller entities within the ScoreCM group of companies:

What kind of personal information do we collect and store?

As part of our business, we collect personal data from customers and potential customers that includes the following:

• Contact information (name, surname, email address, etc.)
• Date of birth and gender
• Information about your income and wealth (including details about your assets and liabilities, account balances, trading statements, tax and financial statements)
• Profession and employment details
• Location data
• Knowledge and experience in trading, risk tolerance and risk profile
• Device information and other data related to your trading activity (IP address, device specifications, etc.)
• Bank account, e-wallet, and credit card details
• Details of your visits to our website or apps, including traffic data, location data, weblogs, and other communication data
• We use cookies to store and collect information about your use of our website. Cookies are small text files that store information on your device. They send information back to our server when you access our website. You can find out more about our cookies in our separate Cookies Policy available on our website.
  • We also keep records of your trading behavior, including:
  • Products you trade with us
  • Historical data about your trades and investments

We are required by law to identify you if you are opening a new account. Anti-money laundering laws require us to sight and record details of certain documents (e.g., passport, ID card, utility bills) to meet the standards set under those laws.

We may also collect your information from third parties, such as public sources, social media platforms, introducing brokers, or credit bureaus.

We may ask for other personal information voluntarily from time to time (for example, through surveys or special offers). If you choose not to provide the information we need, we may not be able to provide you with the requested product or service.

We may record your communications with us, including electronic communications, phone calls, and in-person interactions. These recordings will be our property and will constitute evidence of the communications between us.

Who may we disclose personal information to?

We may disclose your information to:

• Other companies within the ScoreCM group
• Third-party service providers
• Introducing brokers and affiliates
• Payment service providers and banks
• Auditors, contractors, or other advisors
• Courts, tribunals, and regulatory authorities as required by law
• Government bodies and law enforcement agencies as required by law

We endeavor to disclose only the minimum amount of personal data necessary to third parties. Our third-party service providers are not permitted to share or use your data for any purpose other than providing services to ScoreCM.

Our websites or apps may have links to external websites. Please note that these third-party websites are not covered by this Privacy Policy and have their own privacy standards.

When and how do we obtain your consent?

We may process your personal data based on one or more legal grounds depending on the specific purpose for which we are using your data. These legal grounds include:

• Performing our contractual obligations to you
• Complying with legal and regulatory requirements
• Pursuing our legitimate interests

Where our use of your personal information does not fall under one of these legal grounds, we will require your consent. You have the right to withdraw your consent at any time by contacting us using the contact details set out in this Privacy Policy.

We may use your personal data to communicate with you for marketing purposes, such as providing you with market news and analytical reports.

Management of Personal Information

ScoreCM is committed to safeguarding and protecting your personal data. We implement and maintain appropriate technical and organizational measures to ensure a level of security appropriate to protect any personal data you provide us from:

• Accidental or unlawful destruction
• Loss
• Alteration
• Unauthorized disclosure
• Unauthorized access to personal data transmitted, stored or otherwise processed

Data Protection Officer

We have appointed a Data Protection Officer (DPO) to ensure that our management of personal information complies with this Privacy Policy and applicable legislation.

Data Security Practices

Organizations outside the ScoreCM group that handle or obtain personal information must acknowledge the confidentiality of this information. They are obligated to:

• Respect any individual's right to privacy
• Comply with all relevant data protection laws and this Privacy Policy

Here's a summary of the data protection measures we have in place:

• Employee Training: Our employees who handle personal information receive training on respecting customer information confidentiality and individual privacy.
• Access Controls: Employees are required to use strong passwords and two-factor authentication to access our systems.
• Data Segregation: We implement data minimization practices (Chinese Walls) so employees only access personal data necessary for their specific tasks.
• Data Encryption: Data encryption technologies are used during internet transactions and for transmitting client access codes across networks.
• Security Systems: We employ firewalls, intrusion detection systems, and virus scanning tools to protect against unauthorized access and malware.
• Secure Data Transmission: Dedicated secure networks or encryption are used when transmitting electronic data for outsourcing purposes.
• Physical Security:We maintain a clean desk policy and secure storage for physical records across all our premises.
• Access Management: Physical and electronic access controls (access cards, cameras, guards) are used to protect against unauthorized physical access.

How We Store and Retain Personal Information

ScoreCM stores your personal information in a combination of secure computer storage facilities and paper-based files and other records. We take steps to protect your personal information from misuse, loss, unauthorized access, modification, or disclosure.

When we determine that personal information is no longer required, we remove any details that could identify you or securely destroy the records.

However, we may need to retain records for a significant period of time. Here are some examples:

• Investment Services and Anti-Money Laundering Laws: We are subject to laws that require us to retain copies and evidence of actions taken regarding your:
  • Identity verification
  • Sources of income and wealth
  • Transaction monitoring
  • Phone, chat, and email communication
  • Order and trade history
  • Complaint handling
  • These records must be maintained for at least five years after our business relationship ends, or even longer if regulators require it.
• These records must be maintained for at least five years after our business relationship ends, or even longer if regulators require it.

For prospective clients who apply to open an account but never complete the registration or whose application is rejected, personal data will be maintained for six months unless regulations require a longer retention period.

If you opt out of receiving marketing communications, we will add your details to a suppression list to ensure you don't receive them in the future.

Your Rights

You have certain rights regarding your personal information held by ScoreCM. These rights may not apply in all situations. Here's a breakdown of your rights:

• Right to Access: You can request access to your personal data. This is commonly known as a "data subject access request."
• Right to Rectification: You can request correction of any inaccurate personal data we hold about you.
• PrivacyPolicy.Li51.StrongYou can request deletion of your personal data. However, we may not always be able to fulfill this request due to specific legal reasons. We will notify you of these reasons if applicable.
• Right to Erasure (Right to be Forgotten): You can object to the processing of your personal data when we rely on a legitimate interest (ours or a third party's) and you feel it impacts your fundamental rights and freedoms. You can also object to processing for direct marketing purposes. In some cases, we may demonstrate compelling reasons to override your objection.
• Right to Restriction of Processing: You can request to restrict the processing of your personal data in certain scenarios:
  • To verify the accuracy of your data.
  • If our use of the data is unlawful, but you don't want us to erase it.
  • If you need us to retain your data even if we no longer require it, for legal purposes.
  • While your objection to our use of your data is being reviewed.
• Right to Data Portability: You can request to transfer your personal data to yourself or a third party. We will provide your data in a structured, commonly used, and machine-readable format. This right only applies to automated data you initially provided consent for us to use or data used to perform a contract with you.
• Right to Withdraw Consent: You can withdraw your consent at any time when we rely on your consent to process your personal data.

Exercising Your Rights

To exercise your rights, please submit a request by email using the registered email address associated with your account to info@scorecm.com. Erasure requests can also be submitted through your online portal (if available).

We strive to respond to all requests within one month. In complex cases or if you make numerous requests, it may take us longer. We will notify you within one month of receiving your request and keep you updated.

Fees

We may charge a reasonable fee for requests that are manifestly unfounded, excessive, repetitive, or for requests for additional copies of the same data. We will notify you of any fees before processing your request. You may choose to withdraw your request if a fee applies.