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Privacy Policy

GO MARKETS PTY LTD, MAURITIUS - PRIVACY POLICY 1. Introduction GO Markets Pty
Ltd (MU) (“GO Markets”, “we”, “our”, “us”) is as of the 20th of February 2020
registered under Global Business Company Category and holds licence number
GB19024896 as an Investment Dealer (Full Service Dealer, excluding Underwriting)
from the Financial Securities Commission, Mauritius. The Company has developed
the following Privacy Policy (“the Policy”) that covers the collection, use and
disclosure of personal information, as well as the access to and correction of
that personal information by the individuals concerned. GO Markets collects,
processes and discloses personal information about individuals in several
circumstances. The collection, use, storage, disclosure, right of access and
correction of personal information by the GO Markets is governed by the
Mauritian Data Protection Act 2017 (DP Act). Mauritian Data Protection Act 2017
sets out the rules for information matching and provides on how the personal
information is treated. These principles reflect internationally accepted
standards for personal information handling. 2. International Privacy Scene
Mauritian laws are just one part of a world-wide picture of privacy protection.
Privacy is protected as a human right at the highest international level. 2.1.
UN Instruments The United Nations has adopted provisions or instruments that
protect privacy. For example: a. Article 12 of the Universal Declaration of
Human Rights; b. Article 17 of the International Covenant on Civil and Political
Rights. 2.2. OECD and APEC Several international bodies have developed more
detailed guidelines for information privacy protection. a. OECD Guidelines on
Protection of Privacy and Transborder Flows of Personal Data (1980) b. APEC
Privacy Framework (2005) 2.3.APPA Asia Pacific Privacy Authorities (APPA) - is
the principal forum for regional privacy authorities to form partnerships and
exchange ideas about privacy regulation, new technologies and the management of
privacy enquiries and complaints. 2.4.Other International Networks There are
also several other international meetings of privacy regulators which the
Privacy Commissioner and his staff contribute to. These are: a. International
Conference of Data Protection and Privacy Commissioners Privacy Policy GO
Markets Pty Ltd (MU) Privacy Policy 3 Licence No.GB 19024896. Company No.170969
Version: July 2022 b. Global Privacy Enforcement Network (GPEN) c. International
Working Group on Data Protection in Telecommunications (IWGDPT) The following
Execution Policy shall bind the parties, supplement the terms of the Account
Application, and Terms and Conditions, and shall apply to all existing
arrangements currently operating between the parties. 2.5.European Union General
Data Protection Regulation (EU) 2016/679 (the GDPR) Data subject: A data subject
means an identified or identifiable individual, in particular by reference to an
identifier such as a name, an identification number, location data, etc. For GO
Markets it will include, for example, employees, contractors, customers, job
applicants, suppliers, shareholders and directors. Controller: A controller
means a person who or public body which, alone or jointly with others,
determines the purposes and means of the processing of personal data and has
decision making power with respect to the processing. GO Markets is the
Controller in relation to your personal data. Processor: means a person who, or
public body which, processes personal data on behalf of a controller. Consent:
means any freely given specific, informed and unambiguous indication of the
wishes of a data subject, either by a statement or a clear affirmative action,
by which he signifies his agreement to personal data relating to him being
processed. 3. GO Markets’ Obligations This Privacy Policy sets out our
commitment to protecting the privacy of personal information provided to us, or
otherwise collected by us, offline or online, including through this website
www.gomarkets.com/en In this Privacy Policy we, us or our means GO Markets Pty
Ltd (MU). When we collect, store and use your personal information, we do so in
accordance with the rules set down in the Mauritius Data Protection Act 2017. We
are committed to being open and transparent about how we use your personal
information. GO Markets complies with the obligations of the Data Protection Act
2017 and is committed to protecting privacy of your personal data. GO Markets
has a responsibility to ensure that its employees adhere to the Policy and is
responsible for any actions an employee takes in the course of their employment,
or if an employee uses personal information they obtained in the course of their
employment. However, GO Markets will do everything reasonable to prevent its
employees from acting in this way. In such cases, the individual may be held
directly liable. GO Markets is responsible for the personal information it holds
directly and all personal information that it provides to any third party acting
on its behalf. If GO Markets must give information to someone else to allow a
service to be provided, it will do everything reasonable within its power to
prevent the unauthorized use or disclosure of that information by the recipient.
The secure destruction of documents should be a condition of the contract. 4.
Personal Information Personal information: The types of personal information or
personal data we may collect about you include: • Your name, your title; • Your
contact details, including email address, mailing address, street address and/or
telephone number; Privacy Policy GO Markets Pty Ltd (MU) Privacy Policy 4
Licence No.GB 19024896. Company No.170969 Version: July 2022 • Your age and/or
date of birth; • Your drivers’ licence number; • Your employment details; • Your
tax file number; • Financial information including your average taxable income
for the last three years, your statement of income, assets and liabilities; •
Trading statements; • Details of your nominated bank account; • Your preferences
and/or opinions; • Information you provide to us through customer surveys; •
Details of products and services we have provided to you and/or that you have
enquired about, and our response to you; • Your browser session and geo-location
data, device and network information, statistics on page views and sessions,
acquisition sources, search queries and/or browsing behaviour; • Information
about your access and use of our Site, including using Internet cookies, your
communications with our Site, the type of browser you are using, the type of
operating system you are using and the domain name of your Internet service
provider; • Additional personal information that you provide to us, directly or
indirectly, through your use of our Site, associated applications, associated
social media platforms and/or accounts from which you permit us to collect
information; and • Any other personal information requested by us and/or
provided by you or a third party. We may collect these types of personal
information directly from you or from third parties. 5. Collection and use of
personal information We may collect, hold, use and disclose personal information
for the following purposes: • to enable you to access and use our website,
associated applications and associated social media platforms; • to contact and
communicate with you; • for internal record keeping, know your customer and
administrative purposes; • for analytics, market research and business
development, including to operate and improve our Site, associated applications
and associated social media platforms; • for advertising and marketing,
including to send you promotional information about our products and services
and information about third parties that we consider may be of interest to you;
• to comply with our legal obligations and resolve any disputes that we may
have; and • to consider your employment application. GO Markets will be
responsible to make available personal information if required to Mauritian
Authorities as permitted by law. 6. Legal bases for processing (for European
Economic Area users) If you are an individual in the European Economic Area
(EEA), we collect and process information about you only where we have legal
bases for doing so under applicable European Union laws. The legal bases depend
on the services you use and how you use them. This means we collect and use your
information only where: • we need it to provide you with our services, provide
customer support and personalised features and to protect the safety and
security of our services; Privacy Policy GO Markets Pty Ltd (MU) Privacy Policy
5 Licence No.GB 19024896. Company No.170969 Version: July 2022 • it satisfies a
legitimate interest (which is not overridden by your data protection interests),
such as for research and development, to market and promote our services and to
protect our legal rights and interests; • you give us consent to do so for a
specific purpose; or • we need to process your data to comply with a legal
obligation. If you have consented to our use of information about you for a
specific purpose, you have the right to change your mind at any time, but this
will not affect any processing that has already taken place. Where we are using
your information because we or a third party (e.g. your employer) have a
legitimate interest to do so, you have the right to object to that use though,
in some cases, this may mean no longer using our services. 7. Disclosure of
personal information to third parties GO Markets may transfer your personal data
to a data recipient that is situated other than in the European Economic Area
(EEA) or in a country that is on the European Commission’s list of countries
ensuring an adequate level of protection for the rights and freedoms of data
subjects. If GO Markets does transfer your personal data outside the EEA or to a
country not on the European Commission’s list from time to time, it will do so
following due diligence and provided that the data recipient is the subject of
contractual arrangements imposing, among other things, obligations on it to
ensure that appropriate technical and organisational measures are implemented by
it at all times to prevent the unauthorised or unlawful processing of personal
data, and/or the accidental loss or destruction of, or damage to, personal data,
consistent with the Company’s obligations under the Data Protection Act 2017. We
may disclose personal information to: • third party service providers for the
purpose of enabling them to provide their services, including (without
limitation) IT service providers, data storage, webhosting and server providers,
debt collectors, maintenance or problem-solving providers, marketing or
advertising providers, professional advisors, payment systems operators and
credit reporting agencies (CRA); • our employees, contractors and/or related
entities; • our existing or potential agents or business partners; • sponsors or
promoters of any competition we run; • anyone to whom our business or assets (or
any part of them) are, or may (in good faith) be, transferred; • credit
reporting agencies, courts, tribunals and regulatory authorities, in the event
you fail to pay for goods or services we have provided to you; • courts,
tribunals, regulatory authorities and law enforcement officers, as required by
law, in connection with any actual or prospective legal proceedings, or in order
to establish, exercise or defend our legal rights.; • third parties, including
agents or sub-contractors, who assist us in providing information, products,
services or direct marketing to you. This may include parties located, or that
store data, outside of Mauritius; and • third parties to collect and process
data, such as Google Analytics or other relevant businesses. This may include
parties that store data outside of Mauritius. The third party will only process
your personal information in accordance with written instructions from us. When
we refer to ‘processing’ in this clause and this Privacy Policy in general, we
mean any operation or set of operations which is performed on personal
information, whether or not by automated means, such as collecting, recording,
organising, structuring, storage, adaptation or alteration, retrieval,
consultation, use, disclosure by transmission, dissemination or otherwise making
available personal information. Please note that we use the following third
parties to process your personal information: Privacy Policy GO Markets Pty Ltd
(MU) Privacy Policy 6 Licence No.GB 19024896. Company No.170969 Version: July
2022 • Google Analytics. • MetaQuotes. • LABGroup. • Equifax. • GBG Group. •
World Check. • Trulioo. • Sum Sub. By providing us with personal information,
you consent to the disclosure of your personal information to third parties who
reside outside Mauritius and, if you are an individual located in the EEA, to
third parties that reside outside the EEA. Where the disclosure of your personal
information is solely subject to Mauritian privacy laws (and not subject to the
GDPR), you acknowledge that some third parties may not be regulated by the Data
Protection Act 2017 and if any such third party engages in any act or practice
that contravenes, it would not be accountable under the Data Protection Act 2017
and you will not be able to seek redress under the Data Protection Act 2017.
Where the disclosure of your personal information is subject to GDPR, you
acknowledge that there are risks if the third party outside the EEA engages in
any act or practice that would contravene the GDPR and where there is no
adequacy decision in place with the country outside the EEA or appropriate
safeguards in place with the third party. 8. How we treat personal information
that is also sensitive information Sensitive information is a sub-set of
personal information that is given a higher level of protection under the
Mauritian law. Sensitive information means information relating to your racial
or ethnic origin, political opinions, religion, trade union or other
professional associations or memberships, philosophical beliefs, sexual
orientation, sexual practices or sex life, criminal records, health information
or biometric information. We do not currently collect sensitive information from
you. However, if we do so, we will not collect sensitive information from you
without first obtaining your consent. Provided you consent, your sensitive
information may only be used and disclosed for purposes relating to the primary
purpose for which the sensitive information was collected. Sensitive information
may also be used or disclosed if required or authorised by law. 9. Our
responsibilities as a ‘controller’ under the GDPR Controllers are defined by the
GDPR as natural or legal persons, a public authority, agency or other body to
which personal information or personal data has been disclosed, whether via a
third party or not, and who determines the purposes and means of processing
personal information. We are a controller under the GDPR as we collect, use and
store your personal information to enable us to provide you with our goods
and/or services. Privacy Policy GO Markets Pty Ltd (MU) Privacy Policy 7 Licence
No.GB 19024896. Company No.170969 Version: July 2022 As a controller, we have
certain obligations under the GDPR when collecting, storing and using the
personal information of individuals based in the EEA. If you are an individual
located in the EEA, your personal data will: . • be processed lawfully, fairly
and in a transparent manner by us; • only be collected for the specific purposes
we have identified in the ‘collection and use of personal information’ clause
above and personal information will not be further processed in a manner that is
incompatible with the purposes we have identified; • be collected in a way that
is adequate, relevant and limited to what is necessary in relation to the
purpose for which the personal information is processed; • be kept up to date,
where it is possible and within our control to do so (please let us know if you
would like us to correct any of your personal information); • be kept in a form
which permits us to identify you, but only for so long as necessary for the
purposes for which the personal data was collected; • be processed securely and
in a way that protects against unauthorised or unlawful processing and against
accidental loss, destruction or damage. We also apply these principles to the
way we collect, store and use the personal information of our Mauritian
customers or clients. Specifically, we have the following measures in place, in
accordance with the GDPR: • Data protection policies: We have internal policies
in place which set out where and how we collect personal information, how it is
stored and where it goes after we get it, in order to protect your personal
information. • Right to ask us to erase your personal information: You may ask
us to erase personal information we hold about you. • Right to ask us to
restrict data processing: You may ask us to limit the processing of your
personal information where you believe that the personal information we hold
about you is wrong (to give us enough time to verify if the information needs to
be changed), or where processing data is unlawful and you request us to restrict
the processing of personal information rather than it being erased. •
Notification of data breaches: We will comply with the GDPR in respect of any
data breach. 10.Your rights and controlling your personal information a. Choice
and consent: Please read this Privacy Policy carefully. By providing personal
information to us, you consent to us collecting, holding, using and disclosing
your personal information in accordance with this Privacy Policy. You must be 18
years and over to use our Site. You do not have to provide personal information
to us, however, if you do not, it may affect your use of this Site or the
products and/or services offered on or through it. b. Information from third
parties: If we receive personal information about you from a third party, we
will protect it as set out in this Privacy Policy. If you are a third party
providing personal information about somebody else, you represent and warrant
that you have such person’s consent to provide the personal information to us.
c. Restrict: You may choose to restrict the collection or use of your personal
information. If you have previously agreed to us using your personal information
for direct marketing purposes, you may change your mind at any time by
contacting us using the details below. If you ask us to restrict how we process
your personal information, we will let you know how the restriction affects your
use of our Site or products and services. Privacy Policy GO Markets Pty Ltd (MU)
Privacy Policy 8 Licence No.GB 19024896. Company No.170969 Version: July 2022 d.
Access and data portability: You may request details of the personal information
that we hold about you. You may request a copy of the personal information we
hold about you. Where possible, we will provide this information in CSV format
or other easily readable machine format. You may request that we erase the
personal information we hold about you at any time. You may also request that we
transfer this personal information to another third party (data portability).
However, it is a legislative requirement that we keep all personal information
and records for a period of 7 years from the date you close your account with
us. e. Correction: If you believe that any information we hold about you is
inaccurate, out of date, incomplete, irrelevant or misleading, please contact us
using the details below. We will take reasonable steps to correct any
information found to be inaccurate, incomplete, misleading or out of date. f.
Complaints: If you believe that we have breached the Mauritian Privacy laws or
an article of the GDPR and wish to make a complaint, please contact us using the
details below and provide us with full details of the alleged breach. We will
promptly investigate your complaint and respond to you, in writing, setting out
the outcome of our investigation and the steps we will take to deal with your
complaint. You also have the right to contact the Office of the Data Protection
Commissioner at the address below: Data Protection Office Level 5 SICOM Tower,
Wall Street, Ebene. Please consult the Data Protection Office website for
further information at https://dataprotection.govmu.org/ g. Unsubscribe: To
unsubscribe from our e-mail database or opt-out of communications (including
marketing communications), please contact us using the details below or opt-out
using the opt-out facilities provided in the communication. 11.Storage and
security We are committed to ensuring that the personal information we collect
is secure. In order to prevent unauthorised access or disclosure, we have put in
place suitable physical, electronic and managerial procedures such as the
pseudonymisation and encryption of personal information, to safeguard and secure
personal information and protect it from misuse, interference, loss and
unauthorised access, modification and disclosure. We cannot guarantee the
security of any information that is transmitted to or by us over the Internet.
The transmission and exchange of information is carried out at your own risk.
Although we take measures to safeguard against unauthorised disclosures of
information, we cannot assure you that the personal information we collect will
not be disclosed in a manner that is inconsistent with this Privacy Policy.
12.Cookies and web beacons We may use cookies on our Site from time to time.
Cookies are text files placed in your computer’s browser to store your
preferences. Cookies, by themselves, do not tell us your email address or other
personally identifiable information. However, they do allow third parties, such
as Google and Facebook, to cause our advertisements to appear on your social
media and online media feeds as part of our retargeting campaigns. Privacy
Policy GO Markets Pty Ltd (MU) Privacy Policy 9 Licence No.GB 19024896. Company
No.170969 Version: July 2022 If and when you choose to provide our Site with
personal information, this information may be linked to the data stored in the
cookie. We may use web beacons on our Site from time to time. Web beacons (also
known as Clear GIFs) are small pieces of code placed on a web page to monitor
the visitor’s behaviour and collect data about the visitor’s viewing of a web
page. For example, web beacons can be used to count the users who visit a web
page or to deliver a cookie to the browser of a visitor viewing that page. We
may use Google Analytics to collect and process data. To find out how Google
uses data when you use third party websites or applications, please see
https://policies.google.com/technologies/partner-sites or any other URL Google
may use from time to time. 13. Links to other websites Our Site may contain
links to other websites. We do not have any control over those websites, and we
are not responsible for the protection and privacy of any personal information
which you provide whilst visiting those websites. Those websites are not
governed by this Privacy Policy. 14.Amendments We may, at any time and at our
discretion, vary this Privacy Policy. We will notify you if we amend this
Privacy Policy, by contacting you through the contact details you have provided
to us. Any amended Privacy Policy is effective once we notify you of the change.
For any questions or notices, please contact our Data Protection Officer at: GO
Markets Pty Ltd (MU) Email: compliance.mu@gomarkets.com Version: July 2022

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