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Privacy

VIX & GREEX understands how important the privacy and security of the personal data you entrust to us is to you. All VIX & GREEX divisions are focused on protecting the personal information of customers, employees, resellers, applicants and others inside or outside of VIX & GREEX. Therefore, we have developed specific policies and practices to protect your personal data. By opening an account or using VIX & GREEX products and services, you agree to collect and store your personal information by the rules described below. We strongly recommend that you read these terms carefully.
 

They are based on the data protection and privacy principles of the countries where we do business and inform our existing/prospective clients, job applicants, site visitors and others of the policies that apply to them.
 

This policy specifically applies to those individuals who provide their personal information to VIX & GREEX or who visit/use VIX & GREEX websites, trading platforms, software and social media.
 

Who is responsible for your personal data?
 

VIX & GREEX is responsible for customers' personal data, which we may collect in accordance with the principles described below.
 

What personal data do we collect, and how?
 

VIX & GREEX collects and processes your personal data. They may, among other things, contain information that:

• was provided during the process of registering a VIX & GREEX account or using any modules of the VIX & GREEX website (for example, your name, email address, phone number, date of birth, tax number, investment purposes, etc.);

• derived from transactions you make through VIX & GREEX or in connection with services offered by VIX & GREEX (e.g. debit card programme);

• obtained through cookies on the Internet (for more information on how we use cookies, see the "Cookie Policy").
 

For what purposes do we use your personal data?
 

We may use your personal data for the following purposes (so-called "permitted purposes"):
 

• To provide you or your organization with administrative, accounting and legal control services based on an agreement that you or your organization has entered into with us;

• To provide you or your organization with the services available on our platforms and/or to process any of your requests;

• To pursue legitimate interests, including carrying out, monitoring and analyzing our business or operations, including the activities described in this notice;

• To enforce any agreements and/or protect our (or someone else's) property or rights and to dispute possible claims;

• To respond to your requests for information and to contact you in case you need further assistance;

• To contact you (if you opt-out) about features and offers that may be of interest to you;

• For the conclusion or performance of various contracts;

• For surveillance by us or on our behalf, using a variety of methods, including: (i) the use of "reasonable" automated monitoring tools; or (ii) random monitoring of systems, for example through electronic communications recording tools; (iii) purposeful monitoring of systems, for example, in connection with an investigation, a regulatory order, a subject's request for access to personal data, litigation, arbitration; or (iv) data tracking, aggregation and analysis tools that take information from various disparate sources in order to identify relationships and/or behaviors/interactions/preferences for further analysis (including predictive); and/or (v) the use of newly released monitoring technologies of this type;

• To maintain statistics, market research and product analysis, and to develop and improve our range and services;

• To detect and prevent money laundering, terrorism, fraud or other criminal activity and/or misuse of our services;

• To comply with legal/regulatory requirements and good practice standards both in Ireland and elsewhere (e.g. the US) and to comply with our obligations under periodic reporting agreements with the tax authorities;

• To comply with applicable laws of any country;
 

Your personal data may be processed (after obtaining your permission, if

required by law) according to your preferences for the following purposes:
 

• Communicate with you through your approved channels to provide you with the latest news, announcements and other information about VIX & GREEX services, products and technologies.

• Conducting surveys, marketing campaigns, market analysis or promotional activities;

• Collecting information about your preferences to personalize and improve the quality of communication with you (for example, tracking newsletters or site analytics).
 

If required by law, we will only begin sending marketing communications upon your request; you will always have the option to opt out of this service. We prefer to keep our clients, employees and other stakeholders up to date, including those VIX & GREEX news that we think will be useful to them. Please let us know if you do not want to receive such newsletters or information about events and seminars. To the extent permitted by law, we will not use your personal data for

automatically making decisions that affect you or creating profiles other than those described above.
 

Depending on which of the above-permitted purposes we use your personal information, we may process it on the following legal bases:
 

• Following your instructions or the terms of a contract entered into with you or taking the steps necessary to enter into such a contract;

• Fulfilling our legal obligations (e.g. keeping records for tax purposes);

• Where the processing is necessary for our legitimate interests or the interests of any third parties receiving your personal data, provided that this is not contrary to your interests or fundamental rights and freedoms.

In addition, the use of your data may be based on the permission we obtain directly from you.
 

To whom and under what circumstances we disclose your personal data
 

We may share your personal data in the following cases:

• Your personal information may be shared with various VIX & GREEX entities in accordance with applicable laws or requirements for providing services and products, as well as for management, billing and other business purposes. The list of countries in which VIX & GREEX divisions are located is on our website;

• We may instruct local or foreign vendors, both within and outside of VIX & GREEX and, to use personal data for authorized purposes on our behalf and in accordance with our policies. For example, if you subscribe to a third-party service available on the Site, we may provide the relevant provider with the information they need to provide the services you have requested. As a general rule, VIX & GREEX obliges such providers to sign a confidentiality agreement under which they can use the acquired information only for specific needs. This agreement prohibits the service provider from using customer information received from VIX & GREEX for any other purpose than to fulfill the obligations for which this information was disclosed. Where required by law, VIX & GREEX will retain control and responsibility for your personal data and will take reasonable precautions to ensure the integrity and security of your information when dealing with service providers;

• We may share your personal information with fraud and crime prevention and other related firms, including financial institutions such as credit reference agencies and regulators;

• We may disclose information about you to any custodians, exchanges, clearing/settlement systems, account inspectors or other participants in the current structure, counterparties, dealers, trustees, intermediaries and other persons in situations where disclosure of the information is necessary for the implementation, control and recording of transactions within the scope of our services.

• It is possible that your personal data will be disclosed to third parties during the recruitment process;

• Subject to applicable law, we may share your personal information with courts, law enforcement, regulators, law firms, and other agencies for the purpose of filing, establishing, or challenging a claim or alternative confidential dispute resolution process;
 

We may also use aggregated personal information and statistics to track traffic to various areas of our site and improve our services.

Otherwise, your personal data will only be shared if you direct or authorize it; if we are entitled or required to do so under applicable law or official request; or as required to investigate actual or suspected fraudulent or criminal activity
 

Personal data of others that you provide to us
 

If you provide us with someone else's personal data (for example, relating to your managers, employees or persons with whom you do business), you should ensure that you have the right to disclose it to us and that we can record it in accordance with our current privacy policy.
 

Safe storage of your personal data
 

To the extent permitted by law, we will take the necessary technical and organizational measures to maintain the confidentiality and security of your personal data in accordance with our internal information storage, disclosure and access practices. Your information may be stored in the information systems of our company or its intermediaries, as well as in the form of paper records.
 

Moving personal data outside the European Economic Area (EEA; English EEA) or the UK (if GDPR applies)
 

We allow the transfer of personal information covered by the European or UK General Data Protection Regulation (GDPR) outside the European Economic Area or the UK for the permitted purposes listed above. Destinations may also include countries that do not provide the same level of protection as the laws of your country of residence (for example, laws in the European Economic Area, the United Kingdom or the United States) We will certainly take the necessary precautions when making such international transfers, if required by European or UK GDPR regulations or other relevant laws. For more information about these precautions, please contact us using the means of communication below.

For individuals subject to the GDPR who move their personal data to countries or regions outside the EEA or the UK that the European Commission considers do not provide an adequate level of protection, we have put in place appropriate data transfer mechanisms to keep it secure.
 

Updating your personal data
 

If any of the personal information you provided changes (for example, you get a new email address or decide to cancel your request), please notify our support team through the page on the VIX & GREEX website. We are not responsible for any losses arising from your provision of inaccurate, incorrect or incomplete personal information.
 

How long do we keep your personal data?
 

We store your information in accordance with our internal policies, which define the general standards and procedures for the retention, processing and disposal of personal data. We only hold personal information for as long as necessary to comply with legal, regulatory and business requirements. The retention period may be extended if the retention of your personal data requires a claim, investigation or proceeding.
 

Additional rights for individuals under the GDPR and the Personal Information Protection Law (PIPL) regarding data.
 

If you are a resident of the EEA, the UK or the People's Republic of China and your personal data is located in a VIX & GREEX entity established in the EEA or the UK, you have a number of legal rights under the GDPR in relation to the information we hold. These rights include:

• Obtaining information about the processing of your personal data and viewing them in our system. Please note that in some circumstances we may refuse a request for copies of personal data (in particular, this applies to information subject to the obligation of confidentiality);

• Request to correct your personal data if it is incomplete or incorrect;

• Request to delete your personal data in certain cases. Please note that in some circumstances we may have a legal right to retain information that you have requested to be deleted;

• Request to restrict or prohibit the use of your personal data in certain situations. We reiterate that in some circumstances we may have a legal right to use your information even if you request otherwise.
 

Update to the current privacy policy
 

This "Privacy Policy" was updated on December 19, 2022. We have the right to supplement and adjust this policy from time to time, for example, to reflect changes in the law or in our processes for processing personal information. In the event of such changes, we will post the updated privacy policy on our website. Changes take effect immediately after publication.
 

How to contact us
 

We would love to hear your opinion about the site and our privacy policy. If you have any questions regarding the described rules, we recommend that you contact the support service through the VIX & GREEX website.

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