Privacy Agreement

[This Privacy Policy is provided in a tiered format, so you can click on the specific areas listed below.]

1. Important information, commitment

  In this Privacy Policy, we describe how LEADTECH FX LTD’s product forex5 (” FOREX5, “” We,” “Us”) collects and processes the personal data of its current and potential customers. FOREX5 consists of different legal entities, as described in Section 2 below.Each company in FOREX5 controls the personal data of its customers and is responsible for ensuring fair and legal use of this data. This privacy policy is issued on behalf of FOREX5 and each of its companies.

This Privacy Policy applies to legal and/or natural persons who provide personal data to FOREX5 and/or access and/or use FOREX5’s website, trading platform, software applications, social media and/or any other electronic services (” Electronic Services “).

In FOREX5, we admit that your personal data confidentiality and security is very important to you, so we made to the specific policies and practices to protect your personal data.To protect your personal data to develop appropriate technical and organizational measures need FOREX5, as a way to ensure high level of data protection.
At FOREX5, we acknowledge that the confidentiality and security of your personal data is of the utmost importance to you and therefore we have developed specific policies and methods to protect your personal data. Protecting your personal data requires FOREX5 to have appropriate technical and organizational measures in place as a means of ensuring a high level of data protection.

This Privacy Policy is based on the privacy and data protection principles applicable to the countries in which we operate.We will review and/or revision privacy policy from time to time, in the way we handle your personal data includes any new obligations or arrangement, in order to ensure to comply with any applicable laws and regulations.You will receive notice of any significant revisions to this Privacy Policy through the usual communication channels.
We encourage you to read this privacy policy, and we in the process of collecting or processing of your personal data may in particular cases provide you with any other privacy statement or fair dealing with notice.Read this privacy policy is very important, so that you can fully understand all the logistics related to your personal data. This Privacy Policy is in addition to and is not intended to override any and all other notices we may provide to you from time to time.

2. Who are we and who is responsible for your personal data?
FOREX5 is responsible for collecting your personal data in the manner described below.

Foreign currency hours include:

1. Exinity UK Limited of 1 St. Katharine’s Way, London, England, E1W 1UN

2. Exinity Capital East Africa Limited of Kiganjo House, Rose Avenue, Kilimani, PO Box 50719 – 00200 Nairobi, Kenya

3. Exinity Limited of Rue du Savoir, 5th Floor, 355 NEX Tower, Cybercity Ebene, Republic of Mauritius and their respective affiliates and suppliers (collectively, the “FOREX5 Entities” and each a “FOREX5 Entity”).

For any inquiries regarding the use of your personal data, please send to [email protected]

3. What personal data do we collect and process?

Personal data includes any and all information that can identify an individual, excluding any data whose identity has been removed (i.e., anonymous data).After registration with FOREX5, it is necessary for us to collect your personal data in order to comply with legal obligations such as KYC and other regulatory requirements.By knowing your background and requirements, we can be fair to you, to provide you with the most to meet the requirements of your services, to provide you with appropriate and relevant information, and the processing of your request in a fair and effective way.
We will collect, use, store and transit different types of your personal data that we classify as follows:

1. Identity data Example first name, maiden name, surname, proof of identity, username or similar identifier, title, date and place of birth, gender, country of residence and citizenship.

2. contact data, Example billing address, shipping address, email address, phone number, address proof.

3. Professional data:Example education level, occupation, employer name, work experience, financial awareness, trading experience.

4. Tax data:Example tax country of residence, tax identification number.

5. Financial data:example annual income, net assets, sources of funds, expected account turnover, bank accounts, bank statements, payment card details and their copies, e-wallet information.

6. Transaction data:example your payment details, information about the products and services you have purchased from us, method of deposit, purpose of transaction with us.

7. Technical data :Example Internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in type and version, operating system and platform and other technical and electronic services on the device you use to access the FOREX5 website.

8. Personal data:example your user name and password, your purchase or order, your interests, preferences, feedback, survey responses.

9. Usage data: example information about how you use our website, products, services.

Marketing and communications data:example your preferences in receiving marketing from us and any third party companies on our behalf and your communication preferences.We may also collect, store and use the following types of sensitive personal information:

Information about criminal convictions and crimes

We also collect, use and share the summary data, such as statistics or demographics. Non-personal data may come from your personal data but is not considered personal data for legal purposes as such data does not in any way directly or indirectly reveal your identity. For example, we might aggregate your usage data to calculate the percentage of users who visit specific websites and e-service features.But, if we will be in the form of either directly or indirectly identify your identity summary data or connection with your personal data, we will merge data as personal data, and used in accordance with the privacy policy.

4. How do we collect your personal information?
We use different methods to collect your personal data, such as:
Direct interaction.You can fill in the required in our website, electronic service registry or by phone, email or other way to contact us, provide us with your identity, contact information and financial data. This includes, but is not limited to, your personal data provided to us in the following circumstances:

1. Apply for our products or services;

2. According to the request of the client agreement.

3. through electronic service or use any FOREX5 applications to create an account on our website;

4. due to you by FOREX5 system for trading or FOREX5 services related transactions and provide;

5. subscribe to our service or publication;

6. Request to send you marketing information;

7. Participate in competitions, promotions, or surveys;

8.  Give us feedback·

Automation techniques or interactions. When you interact with our e-services, we may automatically collect technical data about your devices, browsing operations and patterns.We through the use of cookies (more information about the cookies we use, please see our cookies policy), the server logs, and other similar technology to collect the personal data.

A third party or public sources.We might receive from various third party and public sources related to your personal data, as shown below:

1. from Google and other analysis provider’s technical data;

2. from payment service provider’s contact information, financial and trade data;

3. from individuals and the identity of the open source for KYC purpose and contact data, such as the company’s registrar, WorldCheck, Thomson Reuters, any consumer reporting agencies, etc.

We also process personal data that we generate in the course of providing services to you, such as transaction data.

5. For what purpose will we use your personal data?
Based on the following legal basis, we may use your personal data for the following purposes (” Permitted Purposes “) :

Signing or executing our agreement
According to you or your organization may be to provide you with the service agreement with us, for record keeping and compliance procedures;
For you or your group provides our available on the platform of the brokerage and other services and/or treatment you may put forward any request or query;
Respond to your request for information and follow up afterwards to see if any further help is needed.

Abide by our legal obligations
Comply with any applicable laws in any country/region in which we operate;

To prevent and detect money laundering, terrorism, fraud or other crimes and/or misuse of our services;
To comply with any laws, regulations or good practice requirement, and fulfill our signed with any tax authority or tax services from time to time report any obligation under this agreement

To pursue our legitimate interests

For our own administrative and operational procedures;

Used for statistical purposes, market research and product analysis, and to develop and improve our products and services;

Perform, monitor and analyze our business or operations, including the activities specified in this Privacy Policy;

Perform or apply any agreement and/or to protect our property or rights (or others), and to defend any potential claim;

With your consent for marketing purposes
We may also process your personal data according to your preferences (after obtaining your explicit consent where required by law) for the following purposes:

1. communicate with you through channels approved by you in order to keep you informed of the latest developments, announcements and other information regarding the FOREX5 services, products and technologies;

2. Conduct customer surveys, marketing campaigns, market analysis or promotional activities;

3. Collect information about your preferences, create user profile to personalization and improve the quality of our communication and interaction with you (for example, by newsletter tracking or site analysis).

Monitoring by us or any other person on our behalf using a variety of methods, including:

1. Use “intelligent” automated monitoring tools; or

2. Through random monitoring system, for example through the electronic system to monitor communications tools;

3. Specific monitoring of systems, such as those related to investigations, regulatory requests, subject access requests, litigation, arbitration, or mediation;

4. data tracking, aggregation and analysis tools that extract data from a variety of different data sources to map associations and/or detect behavioral patterns, interactions or preferences for analysis (including predictive analytics); and/or

5. Use other similar monitoring techniques that may be available from time to time.

In the case of legal requirements, we will not pass your personal information is used to make decisions affect your any automatic or create the above personal information.

We will use your personal data for the purposes for which we collected it, unless we reasonably believe that we need to use it for another reason and that reason is consistent with the original purpose and the law (in which case your knowledge or consent does not require their use). If you would like an explanation of how to determine the compatibility of the cause with the original purpose, please contact us. If we need to use your personal data for unrelated purposes, we will inform you accordingly and explain the legal basis that allows us to do so. Please note that we may process your personal data when required or permitted by law.

6. Who do we share your personal information with and under what circumstances?

We may be in the following cases to share your personal information:

We mayvbe in the case of the application of law to allow or for providing a product or service and for the purpose of management, billing and other business or purpose of the auxiliary need, on the basis of confidentiality between FOREX5 entities to share your personal information. You can find the list of FOREX5 entities and the country/region where each entity resides here.

We maybe instruct FOREX5 internal or external, domestic or foreign service providers to process personal data on our behalf and in accordance with our instructions for permitted purposes. FOREX5 requires these service providers to enter into agreements with FOREX5 as applicable law may require that these agreements apply to govern the use of any information they receive from us. These agreements prohibit service providers from using FOREX5’s customer information except for the purpose of providing or disclosing such information. FOREX5 retains control of and is responsible for your personal data in accordance with applicable laws and uses appropriate safeguards to ensure the integrity and security of your personal information when working with the service provider.

We maybe will share your personal data with companies that provide services in the field of fraud and crime prevention and with companies that provide similar services, including financial institutions, such as credit reference agencies and regulators.

We maybe in IT, trading platform management, document translation, customer support, marketing and promotion of our services and products, external and internal audit, cloud storage, payment services and bank, and other fields to provide service to share your personal data.

We maybe will share your personal data with third parties to whom we may elect to sell, transfer or merge parts of our business or our assets or FOREX5 entities; In addition, we may seek to acquire other businesses or merge with them.

We maybe will disclose information about you to any depositary institution, stock exchange, clearing or settlement system, account controller or other participant in a related system, counterparty, dealer, custodian, intermediary and others provided that the reasonable purpose of the disclosure is to influence, manage or report on transactions relating to the provision of our services or to establish a relationship for such transactions.

In accordance with applicable law, we maybe will share your personal Data with courts, law enforcement authorities, regulatory authorities or attorneys or other parties to establish, exercise or defend legitimate or equitable claims or for the purposes of alternative dispute resolution proceedings.

Normally, we will only disclose your personal information when you instruct us or authorize us to do so, when applicable law or judicial or official requirements permit or require us to do so, or when necessary to investigate actual or suspected fraudulent or criminal activity.

7. International transmission of personal data

Some FOREX5 entities and our external third parties are located outside your country/region, so processing your personal data may involve transferring data outside your country/region for licensing purposes.

Whenever we transmit your personal Data, we ensure that we provide it with a similar level of protection by implementing at least one of the following protective measures:

1. We will only transfer your personal data to countries that are deemed to provide an adequate level of protection for personal data;

2. In the absence of an adequate level of protection, we will transfer your personal data provided that one of the legal safeguards is in place and if they provide an adequate level of protection for the personal Data, then we have put in place appropriate data transfer mechanisms to ensure that the Personal Data is protected.

If you want to learn more about when we transfer your personal data to use the specific mechanism, please contact us.

If you instruct FXTM to stop using or processing your Personal Data, FXTM has the right to terminate any existing services provided to you immediately (or within a reasonable time as determined by FXTM).

8.Safety and Protection

FOREX5 has taken appropriate security measures to protect the security of its customers’ personal data and prevent any unauthorized or illegal processing, accidental loss, destruction, alteration, disclosure, or damage to its customers’ personal data. FOREX5 implements appropriate technical and organizational measures, such as network traffic encryption, pseudonym, data encryption, two-factor authentication, access manager, toking, clean desktop policies, business continuity and disaster recovery, IT system risk assessment, physical and logical access isolation, and policies for handling personal data breaches. FOREX5 limits access to customers’ personal data to employees, agents, contractors, and other third parties who have a business need to know about it,

9. Phone conversations and electronic records

We record, monitor and process any telephone conversation and/or electronic communication between us by fax, email, social media, electronic messages, whether initiated by FOREX5 or by you. FOREX5 records and/or monitors and/or processes all communications, including any telephone conversations and/or electronic communications that result in or may result in the service of transactions or customer orders, even if such conversations or communications do not result in the closing of any arrangements and/or transactions. The content of any face-to-face conversations and/or correspondence with you may be recorded in the minutes or notes of the meeting. Any such records may be provided to you upon request in the same language in which the services are provided to you.

10. How long will you use my personal data?

We will retain your personal data for as long as necessary to achieve the purposes for which we collect the data, including to satisfy any legal, accounting or reporting requirements. To determine the appropriate retention period for your personal data, we consider any statutory or regulatory retention period, the amount, nature and sensitivity, the potential risk of harm from unauthorized use or disclosure, the purposes for which we are processing it and whether we can achieve these purposes by other means, applicable legal requirements, etc.

11. Your Legal rights

In some cases, you have rights relating to your personal data under Data Protection law:

Request access to your personal information (commonly called a “data subject Access request”). This enables you to receive a copy of the personal information we hold about you to check that we are legally processing such information.

Request a correction of your personal information. This enables you to complete and/or modify any incomplete or inaccurate information accordingly.

Request to delete your personal data. This enables you to request us to delete or remove your personal data if there is no good reason for us to continue processing your personal data. If you have successfully exercised your right to object to processing (see below), we may have unlawfully processed your information, or we have been required to delete your personal data, you also have the right to request that we delete or delete your personal data in compliance with applicable law. Please note, however, that for specific legal reasons, we may not always be able to accommodate your removal requests and, if applicable, we will notify you when you request it.

Object to the processing of your personal data where we rely on legitimate interests (or the legitimate interests of a third party), and your particular circumstances cause you to wish to object to the processing on this basis because you believe it will affect your fundamental rights and freedoms. You also have the right to object to our processing of your personal data for direct marketing purposes.In some cases, we may be legitimate reasons to prove we have a convincing to deal with your information, the above your rights and freedom.

Request restrictions on processing your personal data.This enables you to ask us to suspend processing of your personal data if: (a) if you wish us to ascertain the accuracy of the data; (b) Our use of the data is illegal, but you do not want us to delete it; (c) You need us to keep the data even if we no longer need it because you need it to establish, enforce or defend a legitimate claim; (d) You object to our use of your data, but we need to verify that we have an overriding legal reason to use it.

Data portability rights allow you to access and reuse your personal data across different services for your own purposes. It allows you to easily move, copy or transfer personal data from us to another service provider in a secure and reliable manner.

If you want to exercise any of these rights, please send email to [email protected]

You don’t need to pay fees can access your personal data or to exercise any other rights. However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee.Alternatively, in these cases, we may refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity and ensure that you have access to your personal data or exercise any other rights you have.This is a security measure that ensures that your personal data is not leaked to anyone other than you. We may contact you to ask for information related to your request to speed up our response.

We try to respond to all legitimate requests within a month.If your request is complex or you put forward a lot of request, sometimes we may need more than a month’s time. In this case, we will inform you and update you promptly.

12. Personal data leakage

We have procedures in place to deal with any suspected breach of personal data and will notify you and any applicable regulatory authorities of any breach where we are required to do so by law.If you need more information about how we handle data leakage, please contact us.

13. Protection of minors’ information

Use by Minors We do not collect any personal information from minors under the age of 18.If you are children under the age of 18, please do not provide any personal information to us.If we know the personal information we collect the children under the age of 18, we will immediately take action to remove this information.We attach great importance to the protection of personal information of minors, and any user under the age of 18 is not allowed to register and use the services on our platform. If we find that minors are using our services and products without the consent of their guardians, we will take steps to delete their personal information.

14. Modification of privacy policy

We reserve the right to amend this policy. If we make any material changes to this Policy, we will notify you by Posting on our website or otherwise. We recommend that you review this policy periodically to keep abreast of the latest privacy policies.

15. Our Information

Forex5 is a service provided by LEADTECH FX LTD.If you have any questions or concerns about this Privacy Policy or our data protection practices, please contact us at the followingIf you have any questions or concerns, or need to access, correct, delete or restrict the processing of personal information, or have any questions about changes to this Privacy Policy, please contact us at the following ways

16. Supplement: About reading mobile phone information

Foex5 will read the photo album and camera function of your (user) mobile phone, which is mainly used for user avatar, realname authentication, and other information for security verification. All information uploaded by users will be encrypted and will not be uploaded to third parties, fourth parties, or used in other scenarios. (May 4, 2023)

LEADTECH FX LTD

Address: 2525 Arapahoe Ave, Boulder, Colorado, 80302

Email: [email protected]

We will respond to your request as quickly as possible and work hard to resolve your issue.