A. Personal information we collect

We collect the Personal Data you provide directly to us or which we generate when you open a Silverforsen Account, perform any transactions on the Silverforsen Platform, or use other Silverforsen Services or our websites. This may include:

• Contact information, such as name, home address, and email address;
• Account information, such as username, password, account settings and preferences;
• Financial information, such as bank account numbers, bank statement, and trading information;
• Identity verification information, such as images of your government issued ID, passport, national ID card, or driving licence. Note: US residents may be asked to provide their social security numbers;
• Residence verification information, such as utility bill details or similar information;
• Information regarding the way in which you use our services, such as when you used our services and the specific services used;
• Information relating to communications with us, whether through the Silverforsen websites or via e-mail, over the phone or via any other medium.

We also automatically collect certain computer, device and browsing information when you access the Silverforsen websites or use Silverforsen Services. This information is aggregated to provide statistical data about our users' browsing actions and patterns, and does not personally identify individuals. This information may include:

• Computer or mobile device information, including IP address, operating system, network system, browser type and settings;
• Website usage information.

Finally, we may collect Personal Data from third party partners and public sources, which include:

• Reputational information;
• Financial information;
• Business activities of corporate customers.

We need to collect certain types of information for compliance with legal requirements relating to our anti-fraud/anti-money laundering/counter financing of terrorism/know your customer obligations. If this information is not provided we may not be able to provide a service for you. Your personal data may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defence of a legal claims. We will not delete personal data if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved. We do not perform behavioral tracking of a customer's activities on our Silverforsen websites or across different websites, nor do we allow third-party data collection through our Silverforsen Service save as expressly set out in this Privacy Policy.

It is important to note that the Personal Data we collect on you when you create an account will be retained for the mandatory retention period set forth by applicable law and as necessary for us to maintain an exhaustive documentation of our operations as required from us as regulated professionals, even if your account has not been successfully activated (e.g., if account verification has not been completed) or no transaction has been made using it.

B. Use of cookies and similar technology

The Silverforsen websites are using cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Cookies are typically stored on your computer's hard drive. Information collected from cookies is used by us to evaluate the effectiveness of our Site, analyze trends, and administer the Platform. The information collected from cookies allows us to determine such things as which parts of our website are most visited and difficulties our visitors may experience in accessing our website. With this knowledge, we can improve the quality of your experience on the Platform by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties. We also use cookies and/or a technology known as web bugs or clear gifs, which are typically stored in emails to help us confirm your receipt of, and response to, our emails and to provide you with a more personalized experience when using our Site.

We use third party service provider(s), to assist us in better understanding the use of our Site. Our service provider(s) will place cookies on the hard drive of your computer and will receive information that we select that will educate us on such things as how visitors navigate around our site, what products are browsed, and general Transaction information. Our service provider(s) analyses this information and provides us with aggregate reports. The information and analysis provided by our service provider(s) will be used to assist us in better understanding our visitors' interests in our Site and how to better serve those interests. The information collected by our service provider(s) may be linked to and combined with information that we collect about you while you are using the Platform. Our service provider(s) is/are contractually restricted from using information they receive from our Site other than to assist us.

If you want to avoid using cookies altogether, you can disable cookies in your browser. However, disabling cookies might make it impossible for you to use certain features or our website or services, such as logging on to your Silverforsen Account or making transactions. Your use of our websites or service with a browser that is configure to accept cookies constitutes an acceptance of our and third-party cookies.

For more information about cookies, the types of cookies we use and how we use them please see our Cookie Statement.

C. How we use your personal information

We collect and use your information for a variety of reasons. We need some information to enter into and perform our contract – for example your contact and payment details. Some information processing is required by law due to our anti-fraud screening obligations or in the public interest such as making sure we verify our customers' identities.

Some information is processed because you've given your consent to that, which can be withdrawn in your account preferences and settings. Other information we collect and use because we have legitimate business interests to so, having taken into account your rights, interests and freedoms. We may use your Personal Information to:

• Create and administer your Silverforsen account and generally for accounting, billing, maintenance of legal documentation and claim and dispute management. Related processing operations are necessary for the performance of a contract with you (or to take steps at your request prior to entering into a contract), and for compliance with legal obligations to which we are subject;
• Process your Silverforsen transactions. Related processing operations are necessary for the performance of a contract with you and for compliance with legal obligations to which we are subject;
• Verify your identity in accordance with applicable know-your-customer, money laundering and other financial sector legislation or regulations, including as required for compliance with the Silverforsen Anti Money Laundering Policy, as well as address other law enforcement needs as more fully described in our Terms of Use, and generally as required for compliance with legislation and regulations applicable to Silverforsen. With respect to US residents, we also may share your information with other financial institutions as authorized under Section 314(b) of the US Patriot Act, and with tax authorities, including the US Internal Revenue Service, pursuant to the Foreign Account Tax Compliance Act ("FATCA"), to the extent that this statute may be determined to apply to Silverforsen. Related processing operations are necessary for the performance of a contract with you and for compliance with legal obligations to which we are subject;
• Personalise your Silverforsen service experience. Related processing operations are necessary for purposes of our legitimate interests (that is, improving our services);
• Analyse Silverforsen websites usage, and improve our websites and website offerings. Related processing operations are necessary for purposes of our legitimate interests (that is, improving and promoting our services);
• Help us respond to your customer service requests and support needs. Related processing operations are necessary for the performance of a contract with you, and for purposes of our legitimate interests (that is, improving our services and offering you the best experience);
• Contact you about Silverforsen Services. The email address you provide may be used to communicate information and updates related to your use of the Silverforsen Services.

Automated decisions making

We may make automated decisions on certain matters. For example, we may do this to decide whether we can provide our services to you based on a credit check/risk profiling. Depending on the outcome of the credit check/risk profiling, a decision will be reached automatically as to whether we are able to provide products or services to you based on your credit worthiness.

If you disagree with the decision you are entitled to contest this by contacting us at following email address info@silverforsen.com

D. Marketing

We may also occasionally communicate company news, updates, promotions and related information relating to similar products and services provided by Silverforsen. We may also administer a contest, promotion, survey or other site features as will be more explained on the website. We shall only do this where you have given us your consent or otherwise where we are permitted to do so under DP Law in pursuit of our legitimate interests (that is, promoting our services).

We may share personal data with third parties to help us with our marketing and promotional projects, or sending marketing communications.

If you want to opt out of receiving promotional and marketing emails, text messages, post and other forms of communications from us [or our promotional partners] in relation to which you might receive in accordance with this section, you can best opt out by using one of the following ways:

• Log into your account and update your profile.
• Click "unsubscribe" at the bottom of an email we sent you.
• Contact us at info@silverforsen.com to opt-out.

If you do opt out of receiving promotional and marketing messages, we can still contact you regarding our business relationship with you, such as account status and activity updates, survey requests in respect of products and services we have provided to you after you reserve from us, reservation confirmations or respond to your inquiries or complaints, and similar communications.

A. Disclosures to third parties

There are certain circumstances where we may transfer your personal data to employees, contractors and to other parties.

• We may share information about you with other members of our group of companies so we can provide the best service across our group. They are bound to keep your information in accordance with this Privacy Policy;
• We may also share your information with certain contractors or service providers. They may process your personal data for us, for example, if we use a marketing agency. Other recipients/service providers include advertising agencies, IT specialists, database providers, backup and disaster recovery specialists, email providers or outsourced call centres. Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in connection with the performance of their function;
• We may also share your information with certain other third parties. We will do this either when we receive your consent or because we need them to see your information to provide products or services to you. These include credit reference agencies, anti-fraud databases, screening agencies and other partners we do business with.

Your personal data may be transferred to other third party organisations in certain scenarios:

• If we're discussing selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality;
• If we are reorganised or sold, information may be transferred to a buyer who can continue to provide services to you;
• If we're required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the Police;
• If we are defending a legal claim your information may be transferred as required in connection with defending such claim.

Your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data.

Your information will not be sold, exchanged, or shared with any third parties without your consent, except to provide Silverforsen Services or as required by law.

Silverforsen’s third party service providers are contractually bound to protect and use such information only for the purposes for which it was disclosed, except as otherwise required or permitted by law. We ensure that such third parties will be bound by terms complying with DP Law.

B. Disclosures to legal authorities

We may share your Personal Data with law enforcement, data protection authorities, government officials, and other authorities when:

• Compelled by court order, or other legal procedure.
• Disclosure is necessary to report suspected illegal activity.
• Disclosure is necessary to investigate violations of this Privacy Policy or our Terms of use.

C. International transfers of personal data

We store and process your Personal Data in data centers around the world, wherever Silverforsen facilities or service providers are located. As such, we may transfer your Personal Data outside of the European Union. Some of the countries to which your personal data may be transferred for these purposes that are located outside the EU do not benefit from an adequacy decision issued by the EU Commission regarding protection afforded to personal data in that country. Details of these specific countries can be found here . Such transfers are undertaken in accordance with our legal and regulatory obligations and appropriate safeguards under DP Law will be implemented, such as standard data protection clauses with data recipients or processors approved by competent authorities. A copy may be requested at the address set out in the Contact Us section.