Policy Privacy

'GNT CAPITAL LTD' is committed to complying with applicable laws in all places where we carry out our activities. This is not only vital to our continued success in an increasingly regulated global market, but also reflects our commitment to conducting business in accordance with the highest legal and ethical standards. As a company based in the Cayman Islands with operations throughout the world, including within the European Union, 'GNT CAPITAL LTD' is subject to regulations under the laws of the Member States of the European Union and other countries, which cover the personal information we process about our employees, customers, suppliers and others during our commercial activities.

This Privacy Policy, prepared by the Legal Department and our Data Protection Office, is intended to help you understand these regulations. Our Data Protection Officers and their staff are available to answer any questions you may have. Although the specific technical requirements of the law are outside the scope of this policy, these requirements establish uniform standards of conduct for employees of 'GNT CAPITAL LTD' and its affiliates worldwide who handle information covered by these standards.

Full compliance is a requirement at 'GNT CAPITAL LTD' to help ensure compliance with applicable data privacy and security laws.

Thank you for your time.

RIGHT TO PRIVACY

1. We respect each individual's right to privacy, value our relationship with you, and pride ourselves on maintaining loyalty and respect with each individual customer by providing privacy and security.

2. The provisions of this Policy apply to former clients as well as our current clients and contain how we collect and maintain non-public information about our clients (such as their complete history).

We use the Information we collect from you only when appropriate to provide you with quality service and security. For example, we may use Information collected from you to verify your identity. We may also use this Information to establish and configure your Business Account, issue an Account number, issue Access Codes (username and/or password), record your activity and communicate with you from time to time. The Information you provide to us helps us improve our Services for you, personalize your browsing experience, and inform you about additional products, services or promotions that may be of interest to you. If you ever deactivate your Account with us, we will keep your information on file, but we will only use it to comply with regulatory requirements and to contact you from time to time with the option to reactivate your account. Please note that you may opt out of our information sharing policies at any time by notifying us of your desire to do so as explained below.

   INFORMATION WE COLLECT

   1. We collect information about you when:

a. open an account and provide us with information through electronic registration forms;

b. conduct a transaction with us, including when you deposit and withdraw funds;

c. In addition, from time to time, we may collect information about you from third party entities or agencies, such as information about your credit history.

2. By providing us with information, you are giving us your consent to collect, use and store the information in the manner explained below.

PERSONAL INFORMATION

1. When you apply for or maintain an active account with us, we collect personal information about you for business purposes, such as evaluating your financial needs, processing your requests and transactions, informing you about products and services that may be of interest to you, and providing customer service. Such information may include:

to. Application Information: Information you provide to us on applications and other forms, such as your name, address, date of birth, social security number, occupation, assets and income, as well as information required to contact you, such as your address, telephone number and/or email;

b. Transaction information: information about your transactions with us and our affiliates, as well as information about our communications with you (examples

include your account balances, trading activity, your inquiries and/or our responses);

c. Verification Information: Information necessary to verify your identity, such as your passport or driver's license (examples also include background information we receive about you from public records or from other entities not affiliated with

us); In addition, we may collect other identifiable information, such as identification numbers and/or passport/tax registration numbers; We may also collect demographic information when you open an account, including your gender, date of birth, etc.; We may also need to evaluate your trading experience, average annual income, estimated net worth and make an assessment about your risk factor.

2. You provide us directly with most of the information we collect. To do so, you must complete the electronic forms (including, but not limited to, account opening application forms) that we publish on our online trading platform and voluntarily provide us with other necessary documents.

3. Additionally, you provide us with information when transacting on our systems, communicating with us, or responding to a promotion; The information we collect indirectly may include logging your Internet Protocol (IP) address, software settings, operating system, and cookie usage.

COOKIES

1. Cookies are small files containing information that a website uses to track its visitors, which may be sent from us to your computer and sometimes back. Cookies ultimately help us improve your navigation and the ease of use of our online commerce tool. We may set and access cookies on your computer, allowing us to know which advertisements and promotions bring users to our online commerce tool.

2. Additionally, we may use cookies in connection with our products and services to track your activities on our website(s).

3. Cookies do not contain personally identifiable information. The information we may collect and share is anonymous and non-personally identifiable.

SECURITY TECHNOLOGY

1. We protect your information by using data security technology and tools such as firewalls and data encryption. We use Secure Socket Layer (SSL) encryption technology to protect certain information you send to us. This type of technology protects you from your information being intercepted by anyone other than us while it is being transmitted to us.

2. We work hard to ensure our websites are secure and meet industry standards. We also use other security measures, such as firewalls, authentication systems (e.g.  passwords and personal identification numbers) and access control mechanisms to control unauthorized access to systems and data.

3. We also ask that you use your personal Access Codes (username and password) each time you access your account online. We restrict access to Information in our offices so that only officials and/or employees who need to know the Information have access to it.

SHARING INFORMATION WITH THIRD PARTIES

1. We do not disclose your personal information to third parties except as described in this Policy.

2. In those limited circumstances in which we may disclose your personal information to third parties, such disclosures to third parties may include sharing such information with unaffiliated companies that perform support services for your account or facilitate your transactions with us, including those that provide us professional, legal or accounting advice.

3. Unaffiliated companies that assist us in providing services to you are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information solely in the course of providing such services and solely for the purposes we let's determine.

4. We may also disclose your personal information to third parties to carry out your instructions or in accordance with your express consent.

5. We want you to know that we will not sell your personal information.

SHARING OF INFORMATION WITH OUR AFFILIATES

1. We may share the personal information described above with our affiliates for business purposes, such as, but not limited to, servicing customer accounts and informing customers about new products and services, or to assist in the company's business. , its affiliates or employees, and as permitted by applicable law.

2. Our affiliates may include companies controlled or owned by us, as well as companies that have an ownership interest in our company. The information we share with affiliates may include any of the information described above, such as your name, address, business and account information. Our affiliates maintain the privacy of your information to the same extent as we do, consistent with this Policy.

REGULATORY DISCLOSURE

1. In limited circumstances, we may disclose your personal information to third parties as permitted by or to comply with applicable laws and regulations. For example, we may disclose personal information to cooperate with regulatory authorities and law enforcement agencies to comply with subpoenas or other official requests, and as necessary to protect our rights or property.

2. Except as described in this privacy policy, we will not use your personal information for any other purpose unless we describe how such information will be used at the time you disclose it to us or we obtain your permission.

SOCIAL TRADING PLATFORMS

1. We can offer you the ability to participate in a real-time social trading platform, which integrates a rich community and social features into our online trading facility.

2. Clients who choose to be part of this community/network must agree to be part of the network and share their strategies and performance with other clients who choose to be part of the community/network. Accordingly, if you choose to be part of this community/network, you agree and acknowledge that your username, your photo/avatar (if provided), your state of residence, gender, networks, list of users who follow you, users who copy you, etc., list of users you follow or copy, and any  network status/post/blog and any other content options that allow our customers to interact with each other on such social commerce platform, including, without limitation , all the content and information that may be published therein, as well as such as any comments, feedback, publications and/or all information that you provide to us through our Online Trading Facility and/or through Electronic Messaging, email, fax or telephone in connection therewith, will be considered non-confidential information and non-proprietary (other than your Personal Data and Information, as described above, collectively, the "Content").

3. All results of portfolio and trading information will be considered non-confidential and non-proprietary information and our property. By providing such Content, you specifically grant us a non-exclusive, irrevocable, transferable, sublicensable, royalty-free, worldwide license to use, copy, duplicate, store, perform and/or publish all or any part of your Content, and We will be free to use such Content in any manner or medium, without restriction and without any attribution, royalties or other compensation to you.

4. However, the personal information of the clients who participate in this community/network nor the amounts negotiated will never be disclosed. You can always choose to participate or not participate in this community/network, very easily and at your discretion.

CREDIT INFORMATION

1. We do not share credit information, such as credit history, net worth, or other income information, unless otherwise stated here.

2. In accordance with the recommendations of the Payment Card Industry Security Standards Council, customer card data is protected using transport layer encryption — TLS 1.2 and application layer with AES algorithm and length of 256 bit key.

RECORDING PHONE CONVERSATIONS, EMAILS, INTERNET CONVERSATIONS, MEETINGS AND OTHER COMMUNICATIONS

1. Your telephone conversations, emails, Internet conversations (chat), meetings and other communications with us may be recorded/maintained by us.

2. Such recordings shall be and remain our exclusive property and you shall accept them as conclusive evidence of their content as recorded by us.

3. You agree that we may deliver copies of transcripts of such recordings to any court, regulatory or governmental authority, including, without limitation, in disputes that may arise between you and us. However, technical reasons may prevent us from recording a conversation, and any recordings or transcripts we make will be destroyed in accordance with our normal practice. Accordingly, you should not rely on such recordings being available.

OPT OUT

1. You are not required to provide any personal information that we may request from you; however, if you do not do so, we may not be able to open or maintain your account or provide services to you.

2. While we make every effort to ensure that all information we hold about you is accurate, complete and up-to-date, you can significantly assist us in this regard by notifying us immediately if there are any changes to your personal information. 3. If you do not want your personal information to be disclosed to our affiliates or other third parties as described in this Policy, please contact us by email at:

accounts@gntcapital.com or by fax at the following number: 01800-800-7727, or you can send your request by postal mail to:  Av. Ricardo Margain Zozaya 315, Interior 704 Col. Santa Engracia, San Pedro Garza García, Nuevo León, México, P.C. 66263.

GNT CAPITAL LTD.

4. Include your name, account number, mailing address, email address, and phone number.

5. Please note, however, that if we receive such instructions, we will not be able to service your account and will need to close any open and funded accounts you have.

MONITORING AND REVIEW

1. We will periodically monitor the effectiveness of this Policy and, in particular, the quality of execution of the procedures explained in it and, where appropriate, we reserve the right to correct any deficiencies.

2. We will inform our customers of any material changes to this Policy by posting an updated version of this Policy on our website(s).

CUSTOMER CONSENT

1. By accessing and/or using our website(s) and/or our services, you are consenting to the transmission of your Personal Data (i.e., your Personally Identifiable Information and your payment details) to our subsidiaries and/or Affiliates and to external companies to help us process and/or analyze them as part of the provision of our Services to you, whether inside or outside the European Economic Area.

2. Said Personal Data may also be used for marketing purposes or to carry out market research for us or other companies in our group that may use said Personal Data to draw your attention to products and/or services that may be of interest to you and also to assist in the efficient provision of our services, all in accordance with this Policy.

MISCELLANEOUS

1. We reserve the right to review and/or modify this Policy and its agreements, at our sole discretion, when we consider it appropriate or appropriate.

2. Our Privacy Policy is a policy only, does not form part of our Terms and Conditions of Business and is not intended to be contractually binding or to impose or seek to impose obligations on us that we would not otherwise have, if it were not for the “Data Protection Legislation Personal”.

3. If you have any questions about Privacy and/or Data Protection at 'GNT CAPITAL LTD', please direct your questions to our Compliance Department: accounts@gntcapital.com.

Original publication date: June 2017

Approver: Board of Directors

Owner: GNT CAPITAL LTD

Contact person: CEO

Rating: Privacy Policy

Operational applicability: All staff and clients

Geographic Applicability: Worldwide

Other languages: N/A