PRIVACY POLICY

TeleTrade - DJ International Consulting

Ltd

May 2018

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1. Introduction
1. We are committed to protecting and respecting your privacy. This Privacy Policy
("Policy") describes how we treat information that you provide to us or that we
collect about you.
2. By personal data, we refer to data that may be used to identify you as a person.
Personal data include your name, your address, your telephone number, your e-
mail address, your age, your gender, a part of your credit card number.
Anonymous information, which we are not in a position to relate to you, does not
qualify as personal data.
3. TeleTrade is the personal data controller for the data gathered from you, and will
be responsible for the processing of your personal data and will act as data
controller for the purposes of the Decree issued by the Minister of Finance of
Cyprus for the implementation of the Multilateral Agreement on the Automatic
Exchange of Financial Account Information signed by the Cyprus Government on
October 29, 2014, on the basis of the Common Reporting Standard developed by
the OECD (the “CRS Decree”), the Administrative Cooperation in the Field of
Taxation (Amending) Law of 2016 (ACFT Law) and the General Data Protection
Regulation (EU) 2016/679 (GDPR).
4. We may collect personal data as well as other information when you use the
following services:
 Our websites, including https://www.teletrade.eu/,
https://my.teletrade.eu/? , https://teletrade-dj.it/ , https://teletrade-dj.lv/ru,
https://teletrade-dj.cz/, http://teletrade-dj.ro/, https://teletrade-dj.pl/,
http://teletrade.hu/, https://teletrade.pt/, https://teletrade-dj.lt/,
http://teletrade-dj.gr/ and any other Teletrade sites on which this Policy is
posted (the "Sites").
 Your creation and use of a Teletrade Client Login ID when completing the
registration process at https://my.teletrade.eu/? (a “Client ID”).
 Your creation and use of a Teletrade trading account (an "Account"). For
more information on Accounts and how to create an Account please see
our Legal Documentation.
 Your use of any of our other products and services (including support
services) which may be accessible via a third party platform, web
application or social networking service (together the "Ancillary
Services").
In this Policy we refer to the Sites, the Client Login ID, the Account and
the Ancillary Services together as the "Services".
5. Please read this Policy carefully. If you do not agree to this Privacy Policy,
please do not attempt to use the Services. . By registering an Account with
Teletrade and using our products and Investment Services Teletrade is
legally obliged to collect and process your personal data which is required for
the provision of the services.

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By accepting this Policy, you signify your consent to the collection and other processing of
your personal data in accordance with and for the purposes set out in this Policy

2. Who we are

We ("TeleTrade", "we", "our" and "us") are:

Teletrade-DJ International Consulting Ltd,

Esperidon 5,
4th floor, Strovolos,
Nicosia 2001
Cyprus

We respect your right to privacy and will only process personal data and other information you
provide to us or we collect about you in accordance with applicable privacy and personal data
protection laws.

3. Information we may collect from you

When you use the Services we may collect the following categories of data:

A) When you sign up for our marketing communications, register your general interest in
our products and services at our web-sites, or register a Client Login Page, we collect and
process the following "Client Data":
 Your first name and last name, e-mail address and phone number.

B) When you open a Trading Account, we collect and process the following "Trading
Account Data":
 Your first name and last name, your gender, date and place of birth, country of
citizenship, residential address, e-mail address, telephone number,
 Client Login ID, password, financial background and prior trading experience
required in order to carry out the appropriateness test as per the applicable
regulatory framework
 Employment history & source of funds information required to accept your funds
deposits in accordance with AML legislation.
 Furthermore your jurisdiction(s) of residence, tax identification number, and, in
relation to the account(s), the account number, the account balance or value as of
the end of the relevant calendar year or other appropriate reporting period, as
well as any income generated in the account(s) held with TeleTrade, are gathered
and processed pursuant to the CRS Decrees, the ACFT Law and the GDPR.

C) When you deposit funds to your trading account, we collect and process the following
"Payment Information" that is necessary for the adequate performance of the contract

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 between you and TeleTrade and to allow for the effective compliance with AML legal
obligations by Teletrade:

o A part of your credit card number, and information about your credit card issuer.

D) Financial information necessary to process your orders with respect to Teletrade

Services with the relevant payment merchant, which will only be submitted directly to the
payment merchant under secure protocols. This Information may include the amount of
any payment transactions, the payment instrument used, date and time, payment amount,
payment instrument expiration date, electronic wallet email address, IBAN information
for bank transfers, your address and other related transaction details.When you use the
Services, we may collect and process the following "Tracking Data":
o Location information associated with your IP address when you visit our Sites
o Information relating to your use of our Services including, but not limited to,
information about when and how you use the Services and data traffic
o Log files and statistics in relation to actions taken on our Sites
o Technical information about any device that you use when you visit the Sites such
as your IP address and the browser you are using.

For the collection and processing of Tracking Data on the Sites we use cookies. Their
functionality and your options regarding their use are explained in section 4 herein below.

4. Cookies

 The Sites use cookies and similar technologies that collect Tracking Data to
distinguish you from other users. This helps us to provide you with a good experience
when you access the Sites and use the Services.
 A cookie is a small file of letters and numbers that a website places on your computer
or device when you visit a website. You are given the opportunity to consent to using
of cookies or refuse from them as you enter our Sites. If you have opted out, we only
use the strictly necessary cookies (as described below) and store one permanent
‘compliance’ cookie which tells us that you want to opt out of use of any other
cookies. For more information about cookies, we recommend that you visit
www.allaboutcookies.org.

The cookies that are used on the Sites fall into the categories described below. These descriptions
can help you determine if and how you would like to interact with our Sites and other online
services:

 Strictly necessary cookies

These cookies are essential in order to enable you to navigate the Sites and use certain
features. Without these strictly necessary cookies, the online services provided by the
Sites cannot be provided. It is therefore not possible for you to opt out of use of these
cookies. In addition, the coding language the Sites are written in uses session cookies and

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 their use cannot be avoided. These are deleted each time you close your browser. These
cookies do not store any information about the visitor once the browser is closed.
 Performance cookies
Our performance cookies collect anonymous information about how you use the Sites
and their features. For instance, our performance cookies collect information about which
pages on the Sites are visited most often, which advertisements you view or interact with
on the Sites or other websites on which our advertisements appear and if you receive any
error messages.
 Analytics cookies
The Sites use Google Analytics, a web analytics service provided by Google, Inc.
("Google"). Google Analytics uses "cookies", which are text files placed on your
computer, to help us analyse how users use the Sites. The information generated by the
cookie about your use of the Sites (including your IP address) will be transmitted to and
stored by Google on servers in the United States. In case of activation of the IP
anonymisation, Google will truncate/anonymize the last octet of the IP address for
Member States of the European Union as well as for other parties to the Agreement on
the European Economic Area. Only in exceptional cases, the full IP address is sent by us
to and shortened by Google servers in the USA. On behalf of us, Google will use this
information for the purpose of evaluating your use of the Sites, compiling reports on
website activity for us and providing other services relating to website activity and
internet usage to us. Google will not associate your IP address with any other data held
by Google.
The Sites may use other similar analytics cookies. These cookies are used to collect
information about how visitors use the Sites. The information is collected anonymously,
and used to report on the number of visitors to the Sites, where the visitors have come
from, and the pages they have visited.
Furthermore you can prevent Google’s collection and use of data (cookies and IP
address) by downloading and installing the browser plug-in available under
https://tools.google.com/dlpage/gaoptout. Further information can be found under
http://www.google.com/analytics/terms/gb.html (Google Analytics Terms of Service &
Privacy). Please note that on the Sites, Google Analytics code is supplemented by
"gat._anonymizeIp();" to ensure an anonymized collection of IP addresses (so called IP-
masking). Also, you can prevent Google Analytics to collect such data on behalf of
Teletrade by clicking on the following link: https://tools.google.com/dlpage/gaoptout.
 Functionality cookies
Functionality cookies are used to remember choices you make (such as language
preference, country location, or other online settings) and collect anonymous information.

If you wish to refuse the use of cookies by us or by third parties, you can change your browser
settings to reject cookies. As the means by which you can do this varies from browser to
browser, please visit your web browser's "Help" menu for further details. Please note that, should
you choose to refuse the use of cookies by us, this might impair some of the functionality of the
Sites and the Services.

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5. How we use your information
We may use the information that you provide to us or that we collect about you for the following
purposes:

1. Provision of services. Client Data, Trading Account Data and Tracking Data may be
collected and processed by us to provide you with the Services that you request from us
and to perform the respective Operative Agreement (e.g. Client Agreement, Terms &
Conditions) accepted by you. Data collected for that purpose will only be kept as long as
necessary to provide the requested Services.
2. Compliance with applicable legislation and regulatory framework. Any data collected
may be processed by us to detect, investigate and prevent activities that may be illegal,
that may violate the Operative Agreement and also to comply with the requests for
information of the competent regulatory or lawful authorities. Such data will be kept for a
minimum duration of 5 years after the Account closure in accordance with the current
applicable laws.
3. Creation of additional promotion and advertising:
 We may use the e-mail address registered to your Client Login ID to provide
you with information about products and services related to our Services, if
you agree to this service at the time your Client Login ID is created. You may
also opt-out from use of your e-mail address for this purpose at any time, by
sending an e-mail from the e-mail address registered to your Client Login ID
to support@teletrade.eu stating that you do not wish to receive such
information. Alternatively, you may opt out by following the unsubscribe
instructions at the bottom of each e-mail you receive from us.
 We may use Tracking Data to monitor, improve, or modify the Services and
our operations.
 We may use the e-mail address and/or phone number that you registered
with us via contact forms at our web sites, to provide you with information
about our products, services and promotions, if you agreed to receive this
kind of information while registering with us. You may also opt-out from use
of your e-mail address for this purpose at any time, by sending an e-mail
from the e-mail that was registered with us to support@teletrade.eu stating
that you do not wish to receive such information. Alternatively, you may opt
out by following the unsubscribe instructions at the bottom of each e-mail
you receive from us.

6. Sharing your information

We will not share your personal data with anyone else unless in the following limited
circumstances:

 To the extent that we are required to do so by applicable law, by a governmental/

regulatory body or by a law enforcement agency, or for crime prevention purposes.

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  In order to provide the Services to you, Teletrade is legally required to pass on your
personal data to the relevant tax authorities of the Republic of Cyprus, and they may also
be exchanged with tax authorities in another country or in other countries where You, the
Client may be a tax resident in accordance with the CRS decree, and the ACFT Law.

 In order to provide the Services to you in accordance with the Law L. 87(I)/2017
regarding the provision of Investment services, the exercise of investment activities and
the operation of regulated markets (the Investment Services Law) Teletrade is legally
required to report to the Cyprus Securities and Exchange Commission (“CySEC”),
information about your transactions in financial instruments the underlying of which are
traded on regulated markets. Such information includes your personal details, such as
first name, last name, country of citizenship, date of birth and other personal
identification data.

 . Where necessary to, we may share your personal data with third parties who provide
services to us, TeleTrade uses a variety of third party service providers to help us
provide you with Services you request from us. Service providers may be located inside
of the European Economic Area (“EEA”). Service providers may help us: (i) verify your
identity or authenticate your identification documents, (ii) check information against
public databases, (iii) conduct background or police checks, fraud prevention, and risk
assessment, (iv) perform product development, maintenance and debugging, or (v)
provide customer service, advertising, or payments services. These providers have
limited access to your information to perform these tasks on our behalf, and are
contractually bound to protect and to use it only for the purposes for which it was
disclosed and consistent with this Privacy Policy.

7. Children
We recognize that we have a special obligation to protect personal information obtained from
children. We will not knowingly collect personal information from any child, or process such
information, without parental consent. For the purpose of this Policy, a child means any
individual who is under the age of 18 (or the minimum legal age to consent to the collection and
processing of personal information where this is different under applicable law).

8. Security
Teletrade has implemented all reasonable technical, administrative and physical security
measures to protect the security of your personal information and all client data including the
placing of financial transactions and/ or orders. The whole network communication in the
context of sharing financial and/ or personal information is protected by the use of a password
and followed by encryption.

All received information that the client provides is stored on secure servers and only authorized
staff have access to this information. We take reasonable precautions to prevent the loss, misuse

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or alteration of your personal information. Our employees, contractors and agents may be given
access to your personal information which we collect, but their use shall be limited to the
performance of their duties in relation to facilitating your use of the Services. Our employees,
contractors and agents who have access to your personal information are required to keep that
information confidential and are not permitted to use it for any purposes other than those listed
above or to deal with requests which you submit to us.

9. Third party sites & services

The Services may contain links to other websites operated and services provided by third parties,
including those retailers you enter into a transaction with. Please note that this Policy applies
only to the personal information that we collect through the Services and we cannot be
responsible for personal information that third parties may collect, store and use through their
websites or their services. You should always read the privacy policy of each website you visit
carefully.

If you link, connect, or login to your TeleTrade client login ID via a third party service (e.g.
Google, Facebook etc), the third party service site may send us information such as your
registration and profile information from that service. This information varies and is controlled
by that service or as authorized by you via your privacy settings at that service. If you have
chosen to connect your TeleTrade personal page to a third-party application, you can change
your settings and remove permission for the app by changing your Client Login ID (Personal
Page) setting at any time. You are responsible for keeping your personal information with such
third party applications up-to-date and secure so as to ensure the integrity of your TeleTrade
Client Login Page.

10. Your rights

In addition to your opt-out right under section 5.3., you may exercise the following rights at any
time:

o You may ask us to provide you with copies of the personal information that we hold
about you, or with information about the processing of such information.
o You may ask us to update and correct any out-of-date or incorrect personal
information that we hold about you.
o You may ask us to delete the personal information we hold about you.

If you wish to exercise any of these rights, then please contact us at support@teletrade.eu

Please note that if you request the erasure of your personal information:

 We may retain some of your personal information as necessary for our legitimate
business interests, such as fraud detection and prevention and enhancing safety.

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  We may retain and use your personal information to the extent necessary to comply with
our legal obligations. Please note that we are legally obliged to keep on record all and any
information that pertains to the provision of investment services to you and which is
necessary to fulfill our obligations under the applicable laws for a period of up to 7 years
after account closure.
 Some copies of your information (e.g., log records) may remain in our database, but are
disassociated from personal identifiers.
 Because we maintain security measures to protect our data from accidental or malicious
loss and destruction, residual copies of your personal information may not be removed
from our backup systems for a limited period of time.

Where you have provided your consent to the processing of your personal information by
Teletrade, you may withdraw your consent at any time by sending a communication to us
specifying which exact consent you are withdrawing. Please note that the withdrawal of your
consent does not affect the lawfulness of any processing activities based on such consent before
its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit
the ways in which we use your personal information, in particular where (i) you contest the
accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure
of your personal information; (iii) we no longer need your personal information for the purposes
of the processing, but you require the information for the establishment, exercise or defense of
legal claims.

You have the right to complain to the Data Protection Commissioner’s Office if you feel that
Teletrade has not responded to your requests to solve a problem. You can find their contact
details here: http://www.dataprotection.gov.cy/

11. Changes to this Policy

We may change this Policy from time to time for various reasons such as changes to reflect in
law and regulation, changes in industry practices and technological developments. In case you
have a registered Client Login ID, you will be notified of any changes of this Policy via e-mail to
the e-mail address related to your Client Login ID. The latest version of this Policy will always
be available on the Sites. Any new version of this Policy shall take effect (i) immediately upon
the date of your receipt of the notification e-mail where the changes to this Policy relate to non-
material changes which do not reduce your rights; or (ii) no less than thirty (30) days after your
receipt of the notification e-mail where the changes to this Policy potentially reduce your rights;
or (iii) in case you do not have a registered Client Login ID, the moment they are uploaded to our
Sites.

12. Enquiries
If you have any enquiries about this Policy, or any questions about the use of your personal
information, please e-mail us (support@teletrade.eu) or call us (+357 22 51 44 42).