• Important Information and Commitment

In this Privacy Policy, we explain how Spire Capital Markets Ltd (“we” or “us”) collects and processes the personal data of our existing and prospective clients. Spire Capital Markets Ltd consists of various legal entities, detailed in Section 2 below. Each entity within Spire Capital Markets Ltd manages and ensures the fair and lawful use of personal data. This Privacy Policy is issued on behalf of Spire Capital Markets Ltd and each of its entities.

This policy is directed at individuals and organizations who provide their personal data to Spire Capital Markets Ltd and/or interact with our websites, trading platforms, software applications, social media, and other electronic services (“Electronic Services”).

At Spire Capital Markets Ltd, we understand the importance of confidentiality and security regarding your personal data. To protect your personal information, we have developed specific policies and practices, including implementing technical and organizational measures to ensure a high level of data protection.

Furthermore, Spire Capital Markets Ltd monitors, audits, and documents internal compliance with data protection policies and applicable statutory requirements, including local data protection laws. We continually enhance our data protection practices by assigning responsibilities, raising awareness, and training our staff involved in data processing operations.

This Privacy Policy adheres to the privacy and data protection principles applicable in the countries where we operate. It will be reviewed and/or amended periodically to reflect any new obligations or changes in our data processing practices to ensure compliance with applicable laws and regulations. You will be notified of any significant amendments through the usual communication channels.

We encourage you to read this Privacy Policy carefully, along with any other privacy statements or fair processing notices we may provide when collecting or processing your personal data. This policy supplements other notices we provide and is not intended to override them.

• Who Are We?

This Privacy Policy outlines the data processing activities of Spire Capital Markets Ltd concerning the personal data of its clients/potential clients, website visitors, and employees. It does not apply to websites operated by other organizations or third parties.

Each entity within Spire Capital Markets Ltd has its own Privacy Policy. These entities operate their own websites, and you should refer to their specific privacy statements available on their respective websites to learn about how they process your personal data.

Spire Capital Markets Ltd respects the privacy of all users who access our website(s) and is committed to safeguarding the personal data of existing or prospective clients, applicants, and website visitors. We maintain clients’ and potential clients’ personal data in accordance with applicable data protection laws and regulations.

We have implemented necessary and appropriate technical and organizational measures to ensure your information remains secure at all times. Our employees are regularly trained and made aware of the importance of maintaining, safeguarding, and respecting your personal information and privacy. Breaches of privacy are taken very seriously, and appropriate disciplinary measures, including dismissal, may be imposed when necessary.

The personal information you provide during registration as a user of our site(s) and/or services is classified as registered information, protected in various ways. You can access your registered information after logging into the Members Area with your selected username and password. It is your responsibility to keep your password confidential. Registered information is securely stored and accessible only to authorized personnel via a username and password. Personal information that is not classified as registered information is also securely stored and accessible only to authorized personnel.

• What Personal Data Do We Collect and Process?

Personal data includes any information that can identify an individual and does not include data where the identity has been removed (anonymous data). When you register with Spire Capital Markets Ltd, we collect your personal data to comply with legal obligations such as KYC and other regulatory requirements. This helps us treat you fairly, provide services that best match your needs, offer relevant information, and process your requests efficiently.

We collect, use, store, and transfer various kinds of personal data, grouped as follows:

• Identity Data: Includes first name, maiden name, last name, proof of identity, username or similar identifier, title, date and place of birth, gender, country of residence, and citizenship.
• Contact Data: Includes billing address, delivery address, email address, telephone number(s), and proof of address.
• Professional Data: Includes level of education, profession, employer name, work experience, financial awareness, and trading experience.
• Tax Data: Includes country of tax residence and tax identification number.
• Financial Data: Includes annual income, net worth, source of funds, anticipated account turnover, bank account details, bank statements, payment card details, and e-wallet information.
• Transaction Data: Includes details about payments to and from you, information on products and services purchased from us, deposit methods, and transaction purposes.
• Technical Data: Includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices used to access our website and Electronic Services.
• Profile Data: Includes username and password, purchases or orders made by you, interests, preferences, feedback, and survey responses.
• Usage Data: Includes information about how you use our website and services.
• Marketing and Communications Data: Includes preferences for receiving marketing from us and third parties, and communication preferences.

We may also collect, store, and use sensitive personal information, such as details of criminal convictions and offenses.

We process aggregated data for statistical or demographic purposes. This data is not considered personal as it does not directly or indirectly reveal your identity. For example, we may aggregate usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data in a way that identifies you, we treat it as personal data in accordance with this Privacy Policy.

• How Do We Collect Your Personal Data?

We collect your personal data through various methods:

Direct Interactions: You provide personal data by filling in registration forms on our website, Electronic Services, or by corresponding with us via phone, email, or otherwise. This includes:

• Applying for our products or services
• Making a request under the client agreement
• Creating an account on our website or using any of Spire Capital Markets Ltd applications
• Conducting transactions through Spire Capital Markets Ltd systems
• Subscribing to our service or publications
• Requesting marketing materials
• Entering a competition, promotion, or survey
• Providing feedback

Automated Technologies or Interactions: We automatically collect technical data about your equipment, browsing actions, and patterns as you interact with our Electronic Services using cookies, server logs, and similar technologies.

Third Parties or Publicly Available Sources: We may receive personal data from various third parties and public sources, including:

• Technical data from analytics providers like Google
• Contact, financial, and transaction data from payment service providers
• Identity and contact data for KYC purposes from public sources like the registrar of companies, WorldCheck, Thomson Reuters, and consumer-reporting agencies

We also process personal data generated during our service provision, such as Transaction Data.

• For What Purposes Will We Use Your Personal Data?

We use your personal data for the following “Permitted Purposes” based on specific legal grounds:

To Enter into or Perform Our Agreement:

• Provide services according to the agreement(s) with you or your organization
• Keep records and comply with compliance procedures
• Offer brokerage and other services on our platforms
• Handle requests or inquiries from you

To Comply with Legal Obligations:

• Adhere to applicable laws in countries where we operate
• Prevent and detect money-laundering, terrorism, fraud, or other crimes and abuses of our services
• Fulfill legal, regulatory, or good practice requirements
• Meet reporting obligations with tax authorities or revenue services

To Pursuing Our Legitimate Interests

• Administrative and Operational Procedures: Streamlining our internal processes.
• Statistical Analysis and Market Research: Improving our products and services through analysis and development.
• Communication Updates: Informing you about changes to our services, fees, and charges.
• Marketing Communications: Sending you information about products or services that may interest you, unless you opt-out.
• Consent-Based Processing
• With your consent, we may use your data to provide marketing information or any other details you request.

For more information on the specific purposes we use your personal data for, please refer to Section 7 of this Privacy Policy.

• Sharing Your Personal Information

We may share your personal information in the following circumstances:

• Within Spire Capital Markets Ltd: Sharing data between entities for administrative and service purposes.
• Service Providers: Engaging third-party processors under strict confidentiality agreements to handle data for the permitted purposes.
• Fraud Prevention: Collaborating with companies and financial institutions to prevent fraud and other crimes.
• Operational Support: Working with companies in IT, marketing, auditing, payment services, and more.
• Business Transactions: Sharing data during mergers, acquisitions, or sales.
• Legal Requirements: Disclosing information to regulatory bodies, law enforcement, or in legal proceedings.

• International Data Transfers

Some of our entities and third-party processors are located outside your home country. We ensure a similar level of data protection through appropriate safeguards, such as:

• Adequate Protection Countries: Transferring data only to countries with sufficient data protection laws.
• Legal Safeguards: Implementing mechanisms that provide adequate protection.

Contact us for more details on our international data transfer mechanisms.

• Security Measures

Spire Capital Markets Ltd implements robust security measures to protect your data, including encryption, two-factor authentication, access management, and regular employee training. We limit data access to authorized personnel only.

• Recording Communications

We may record and monitor telephone and electronic communications for quality and regulatory purposes. This includes communications that may not result in a transaction.

• Data Retention

We retain your personal data only as long as necessary for the purposes it was collected, including legal and regulatory requirements. Factors determining retention periods include data sensitivity, potential harm from unauthorized use, and statutory obligations.

• Your Legal Rights

You have several rights regarding your personal data, including:

• Access: Requesting copies of your data.
• Correction: Correcting incomplete or inaccurate data.
• Erasure: Deleting data when it is no longer needed or processed unlawfully.
• Objection: Objecting to data processing based on legitimate interests or direct marketing.
• Restriction: Suspending data processing in certain situations.
• Portability: Moving, copying, or transferring data between services.

To exercise your rights, contact our Data Protection Officer using the provided contact details. We aim to respond to all legitimate requests within one month and may require verification of your identity.

• Data Breach Procedures

We have procedures to handle suspected data breaches and will notify you and relevant regulators as required by law.

For any further information or queries, please contact us directly.Spire Capital Markets LtdSpire Capital Markets LtdSpire Capital Markets LtdSpire Capital Markets LtdSpire Capital Markets Ltd