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Wozinga Group Privacy Policy

At Wozinga Group, we understand that confidentiality and security of the personal information ("Personal Information") that you share with us is important.

The Wozinga Group affiliates (collectively, "Wozinga"), are committed to protecting the privacy of Personal Information, including Personal Information related to individuals who may be clients, employees, agents, job applicants or others inside or outside of Wozinga. That is why we have developed specific policies and practices designed to protect the privacy of your Personal Information.

By opening an account at Wozinga or by utilizing the products, services and applications available through Wozinga, you have consented to the collection, use and disclosure of your Personal Information in accordance with this privacy policy ("Privacy Policy" or "Policy").

We encourage you to read this Privacy Policy carefully.

This Policy is based on the privacy and data protection principles common to the countries in which we operate. This Policy is intended to summarize Wozinga's data protection practices generally and to advise our clients, prospective clients, job applicants, website visitors and other third parties about Wozinga's privacy policies that may be applicable to them. This Policy is specifically addressed to those who provide Personal Information to Wozinga or who visit or use Wozinga's websites, trading platforms, software application and social media sites.

Who is responsible for your Personal Information?

Wozinga is responsible for the Personal Information that we may collect in the manner discussed below. Wozinga includes:

Wozinga LLC, the Company is a registered Limited Company (registration number 3142 LLC 2023), authorised by Financial Services Authority (“FSA”), Its registered office is at Suite 305, Griffith Corporate Centre, Beachmont, Kingstown, Saint Vincent, Wozinga Pty Ltd, (“Wozinga Australia”) is a registered limited company (Company number 625 841 741) It is a Corporate Authorised Representative (CAR Number 001303375) of Pulse Markets Pty Ltd (ABN 14 081 505 268, its registered office is 12 Graham Street, NSW, 2446, Wozinga UAB, (“Wozinga Europe”) is a registered company (Company number 305900234), its registered office is Laisvės pr. 60 05001 Vilnius, Lithuania 159-088-255 and their respective affiliates (the "Wozinga Entities"). Specifically, your Personal Information will be controlled by the Wozinga Entity that is providing services or a communication to you. In some instances your Personal Information will be controlled by more than one Wozinga Entity.

How do we collect your Personal Information and what Personal Information do we collect?

Wozinga collects Personal Information from you. This may include, among other things, information:

provided during the Wozinga account application process or during use of any of Wozinga's website applications (for example, your name, email address, telephone number, birth date, tax ID number, investment objectives, biometric information, etc.);
provided when you apply for an employment opportunity with us (for example, your name, contact information and any additional information provided by you in your resume);
acquired as a result of the transactions you conduct through the Wozinga systems or in connection with services offered by Wozinga (for example, if you participate in Wozinga's debit card program);
received from consumer-reporting agencies;
collected through Internet cookies (for further information on our use of cookies, please see our Cookie Policy).

For what purposes will we use your Personal Information?

We may use your Personal Information for the following purposes ("Permitted Purposes"):

To provide services to you in accordance with any agreement(s) you or your organisation may have with us, for our own administrative, record-keeping and compliance procedures;
To provide you or your organisation with brokerage and other services available on our platforms, and/or to deal with any requests or inquiries you may have;
To pursue legitimate interests, including to carry out, monitor and analyze our business or operations including the activities set out in this Privacy Policy;
To enforce or apply any agreement and/or to protect our (or others') property or rights and to defend any potential claim;
To conduct our recruiting processes (applies only to information submitted for employment applications);
To respond to requests for information from you and to follow up with you afterwards to see if we can provide any further assistance;
To contact you (unless you tell us that you prefer us not to) regarding features and functionality that may be of interest to you;
To enter into or carry out contracts of various kinds;
To conduct monitoring by us or any other person on our behalf using various methods, including:
1. the use of "intelligent" automated monitoring tools; or
2. through random monitoring of systems, for example systematically via electronic communication recording tools;
3. specific monitoring of systems for example in relation to investigations, regulatory requests, subject access requests, litigation, arbitration or mediation or;
4. data tracking, aggregation and analysis tools that pull data from various disparate data sources to draw linkages and/or detect behavioral patterns, interactions or preferences for analysis (including predictive analysis); and/or
5. using other similar monitoring technology that may become available from time to time;
For statistical purposes and for market research and product analysis and to develop and improve our products and services;
For the purposes of preventing and detecting money-laundering, terrorism, fraud or other crimes and/or abuses of our services;
To comply with any legal, regulatory or good practice requirement whether originating from Lithuania or elsewhere (including but not limited to, the Australia), and to fulfil our obligations under any reporting agreement entered into with any tax authority or revenue service(s) from time to time;
To comply with applicable laws in any country. We may also process your Personal Information for the following purposes (after obtaining your express consent where such consent is legally required) in accordance with your preferences:
To communicate with you through the channels you have approved to keep you up to date on the latest developments, announcements and other information about Wozinga services, products and technologies; you;
To conduct client surveys, marketing campaigns, market analysis, or promotional activities;
To collect information about your preferences to create a user profile to personalize and foster the quality of our communication and interaction with you (for example, by way of newsletter tracking or website analytics).

Where legally required, with regard to marketing-related communication, we will only provide you with such information after you have opted in or had an opportunity to object and we will also provide you with the opportunity to opt out at any time if you do not wish to receive further marketing-related communication from us.

We like to keep our clients, personnel and other interested parties informed of company developments, including news relating to Wozinga that we believe is of interest to you. If you do not wish to receive publications or details of events or seminars that we consider may be of interest to you, please let us know by unsubscribing to email communication in you Wozinga profile or following the unsubscribe link at the bottom of received emails.

Where legally required, we will not use your Personal Information for taking any automated decisions affecting you or creating profiles other than described above.

Depending on which of the above Permitted Purposes we use your Personal Information for, we may process your Personal Information on one or more of the following legal grounds:

Because processing is necessary for the performance of your instruction or other contract with you or to take steps prior to entering into any such contract;
To comply with our legal obligations (for example, to keep pension records or records for tax purposes);
Because processing is necessary for the purposes of our legitimate interest or those of any third party recipients that receive your Personal Information, provided that such interests are not overridden by your interests or fundamental rights and freedoms. In addition, the processing may be based on your consent where we have expressly sought and you have expressly given that to us.

We may share your Personal Information between the Wozinga Entities on a confidential basis as allowed by applicable law or where required for the purpose of providing products or services and for administrative, billing and other business purposes. A list of the countries in which Wozinga Entities are located can be found on our website;
We instruct service providers within and outside of Wozinga (including cloud service providers), domestically or abroad, to process Personal Information for the Permitted Purposes on our behalf and in accordance with our instructions and based on our legitimate interest to provide, maintain and improve our products and services. For example, if you choose to subscribe to any services provided by a third-party provider listed on an Wozinga Investors' Marketplace, we may disclose such information to service providers as necessary for them to provide the services that you have requested. Wozinga generally requires these service providers to enter into confidentiality agreements with Wozinga that limit their use of the information that they receive. Such agreements prohibit the service provider from using Wozinga client information that they receive other than to carry out the purposes for which the information was disclosed. If required by law, Wozinga will retain control over and will remain responsible for your Personal Information and will use appropriate safeguards to ensure the integrity and security of your Personal Information when engaging service providers;
We may share your Personal Information with companies providing services in the areas of fraud and crime prevention and with companies providing similar services, including financial institutions such as credit reference agencies and regulatory bodies;
We may disclose information about you to any depository, stock exchange, clearing or settlement system, account controller or other participant in the relevant system, to counterparties, dealers, custodians, intermediaries and others where disclosure is reasonably intended for the purpose of effecting, managing or reporting transactions in connection with the provision of our services or establishing a relationship with a view to such transactions;
We may share data provided to us for employment applications with third parties to assist us with the conduct of our recruitment processes;
Consistent with applicable law, we may share your Personal Information with courts, law enforcement authorities, regulators or attorneys or other parties for the establishment, exercise or defence of a legal or equitable claim or for the purposes of a confidential alternative dispute resolution process;
We may also use aggregated Personal Information and statistics for the purpose of monitoring website usage in order to help us develop our website and our services.

Personal Information about other people that you provide to us

We share your Personal Information in the following circumstances:

Personal Information about other people that you provide to us

We share your Personal Information in the following circumstances:

Keeping Personal Information about you secure

To the extent required by law, we will take appropriate technical and organizational measures to keep your Personal Information confidential and secure in accordance with our internal procedures covering the storage, disclosure of and access to Personal Information.

Transferring your Personal Information outside the European Economic Area ("EEA") (if GDPR) applies) For Personal Information subject to the General Data Protection Regulation (EU) 2016/679 ("GDPR") we may transfer your Personal Information outside the EEA for the Permitted Purposes as described above. This may include countries that do not provide the same level of protection as the laws of your home country (for example, the laws within the EEA or Australia). We will ensure that any such international transfers are made subject to appropriate or suitable safeguards if required by the GDPR or other relevant laws. You may contact us at any time using the contact details below if you would like further information on such safeguards.

With respect to persons covered by GDPR, in case Personal Information is transferred to countries or territories outside of the EEA that are not recognized by the European Commission as offering an adequate level of data protection, we have put in place appropriate data transfer mechanisms to ensure Personal Information is protected.

Updating your Personal Information

If any of the Personal Information that you have provided to us changes, for example if you change your email address or if you wish to cancel any request that you have made of us, please let us know by contacting Wozinga Client Service through the Wozinga website at my.wozinga.com or email customercare@wozingagroup.com.

We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete Personal Information that you provide to us.

How long do we retain your Personal Information?

We retain your Personal Information in an identifiable form in accordance with our internal policies which establish general standards and procedures regarding the retention, handling and disposition of your Personal Information. Personal Information is retained for as long as necessary to meet legal, regulatory and business requirements. Retention periods may be extended if we are required to preserve your Personal Information in connection with litigation, investigations and proceedings.

Further rights for persons or information covered by GDPR the Personal Information Protection Law ("PIPL") With respect to residents of the EEA as well as in situations where your Personal Information is processed by an Wozinga Entity established in the EEA you have a number of legal rights under GDPR in relation to the Personal Information that we hold about you.

These rights include:

Obtaining information regarding the processing of your personal information and access to the personal information that we hold about you. Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information, (in particular, information that is subject to legal professional privilege);
Requesting that we correct your personal information if it is inaccurate or incomplete;
. Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled to retain it;
Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request;
Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so;
Obtaining computerized personal information collected from you in a structured, commonly used and technological format (right to data portability).

We have designated a Data Protection Officer ("DPO") to enhance and promote compliance with and understanding of privacy and data protection principles. If you wish to do any of the above please send an email to customercare@wozingagroup.com.

We may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorized disclosure of data. We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your data and for any additional copies of the Personal Information you request from us

We will consider any requests or complaints that we receive and provide you with a response in a timely manner. If you are not satisfied with our response, you may take your complaint to the relevant privacy regulator. We will provide you with details of your relevant regulator upon request.

Updates to this Privacy Policy

This Privacy Policy was last updated on the date indicated at the top of this Policy. We reserve the right to update and change this Privacy Policy from time to time, for example, in order to reflect any changes to the way in which we process your Personal Information or changing legal requirements. In case of any such changes, we will post the changed Privacy Policy on our website or publish it otherwise. The changes will take effect as soon as they are posted on our website.

How to contact us

We welcome your views about our website and our Privacy Policy. If you have any questions about this Policy, please contact us at customercare@wozingagroup.com