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PRIVACY

EtradeDirect privacy policy

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[ Last update: 24.05.2021 ]

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This Privacy Policy is part of the EtradeDirectTerms of Use ( the "TUP" ).

Terms used in this Privacy Policy will have the same meanings as in the TUPs, except as otherwise noted herein.

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This Privacy Policy explains how Etradedirect and the EtradeDirect operators collect, use, process, disclose, share, transfer and protect personal information obtained through EtradeDirect and its partners. The terms "we", "us" and "our" refer to EtradeDirect and EtradeDirect Operators.

When we request certain personal information from users, it is because applicable laws or government orders require us to collect such information or because it is relevant for our specific purposes.

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Please read the full content of this Privacy Policy carefully.

By visiting EtradeDirect, regardless of whether you register or log in to the EtradeDirect Services, you acknowledge, understand and consent to all items described in this Privacy Policy. We will not use your personal information for any purpose that is not covered in this Privacy Policy or the TUPs (including other EtradeDirect business rules) without prior notice to you and without your consent.

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The most recent Privacy Policy has incorporated elements of the General Data Protection Regulation (GDPR), since we act in accordance with its rules for processing personal information within the Latin American Economic Area.

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We use standard contractual clauses, we rely on the adequacy decisions of the National Securities Market Commission on certain countries, as appropriate, and we obtain your consent for these data transfers to third countries if required by applicable laws.

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1. INFORMATION WE COLLECT

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The following are the types of information we collect when you register and use the EtradeDirect Services:

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1.1 Information you provide to us when registering

When you create an EtradeDirect account, you provide us with your email address, name, date of birth, nationality, country code, gender, signature, utility bills, address, password, and other information to help us identify you (" Identification. ”) You can also choose to add a phone number for SMS or a Google Authenticator account for two-factor authentication to enhance account security.

If you agree to use biometric authentication methods to log in or use EtradeDirect services, such as fingerprint recognition and facial recognition, you must provide us with the relevant information, such as fingerprint information and facial information, and your consent to processing. of your biometric data.

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1.2 Information we collect to comply with regulatory policies

To comply with global industry regulatory standards, local industry regulatory standards, and government orders in different aspects such as Anti-Money Laundering (AML), Know-Your-Client (KYC) and Counter-Terrorist Financing (CTF) , EtradeDirect is required. to collect personal information in addition to identification information, such as identity documents (including passport, driver's license, national identity card, state identification card, tax identification number, passport number, driver's license details, national identity card details, visa information, etc.), proof of address, source of fund statement, purposes of fund documents and source of wealth ("Information We will explain the content and requirements of such personal information to you each time we collect information, and we reserve the right to change the content and requirements of the information collected as global industry regulatory standards change, local regulatory standards or government orders. This provision applies to EtradeDirect accounts both personal and or institutional.

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1.3 Information We Collect While Using EtradeDirect Services

a Information on the use of the service:

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A)Through your access to and use of the EtradeDirect Services, we may monitor and collect usage-related tracking information including, but not limited to, your phone number, date and time of access, device type, and device identification, operating system and hardware configuration, browser type and information derived from the SIM card, network operator, IP address, GPS, base station and WLAN ("Service usage information"). This information can be obtained directly by EtradeDirect or through external service providers. Collecting service usage information helps our systems ensure that our interface is accessible to users on all platforms and can assist during criminal investigations.

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B)Transaction information

For all personal and institutional user accounts, we may collect transaction information as you use the EtradeDirect Services, including but not limited to deposit snapshots, account balances, business history (such as transaction initiation, payment method, price, quantity, time, withdrawal and authorization). information), order activity and distribution history ("Transaction Information"). We collect such transaction information to monitor suspicious business activity for user protection against fraud, legal case resolution, and any other purpose disclosed in this Privacy Policy.

C)Communication information

You agree that, for the purposes disclosed in this Privacy Policy, we have the right to collect and use the information contained in or related to the communication that you send to us or generated through your use of the EtradeDirect Services ("Information from

communication "), which includes:

  1. i. all messages, requests or other information that you send during your contact with EtradeDirect;

  2. ii. all communications and attachments in relation to your transactions with other users or other data generated mainly through your communications with them.

D)Financial information:

You agree that, for the purposes disclosed in this Privacy Policy, we have the right to collect and use the information contained in or related to your financial information when you use the EtradeDirect Services, including but not limited to bank account information, the main account number of the payment card (PAN), transaction history, commercial data and / or tax identification. We collect such financial information to monitor suspicious financial activity for user protection against fraud, resolution of legal cases, and any other purpose disclosed in this Privacy Policy.

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2. HOW WE COLLECT INFORMATION

2.1 Information that EtradeDirect collects automatically

Most of the personal information we collect is provided directly by you. In the following situations, we will collect and process your information:

a. where you register, log in or visit EtradeDirect, or use any EtradeDirect service;

B. where you voluntarily complete any user survey or provide feedback to us via email or any other channel;

C. when you use browser cookies or software when visiting or using our website or applications;

D. other situations where we may automatically collect your information as mentioned in this Privacy Policy or in our TUPs (including the EtradeDirect Platform Rules, the same below).

2.2 Information collected from third party sources

We may collect information about you from third party sources, including but not limited to the following channels:

a. public databases, credit bureaus and identity verification partners;

B. blockchain data;

C. marketing partners and resellers;

D. advertising partners and analytics providers.

2.3 Aggregated and anonymized data

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Anonymization is a data processing technique that removes or modifies personal information so that it cannot be associated with a specific individual. Except for this section, none of the other provisions of this Privacy Policy apply to anonymized or aggregated personal data (that is, information about our Users that we combine so that it no longer identifies or references an individual User).

We may use anonymous or aggregated customer data for any business purpose, including to better understand the needs and behaviors of Users, improve our products and services, conduct business and marketing intelligence, and detect security threats. We can perform our own analysis of anonymous data or enable analyzes provided by third parties.

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3. HOW WE USE THE INFORMATION WE COLLECT

We use the information we collect about you for the following purposes or in the following ways:

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3.1 To provide and maintain EtradeDirect services

We use the information collected to deliver, maintain and provide better EtradeDirect Services (including but not limited to transaction processing) and to verify the identities of Users.

We use the IP address and unique identifiers stored in your device cookies to help us authenticate your identity and activities and to provide the EtradeDirect Services. Given our legal obligations and system requirements, we cannot provide some or all of the EtradeDirect Services to you without data such as Identification Information, Monitoring Information, Service Usage Information, Communication Information, and Transaction Information.

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3.2 To protect our users

We use the information collected to protect our platforms, user accounts and files.

We use IP addresses and cookies to protect against automated abuses such as spam, phishing, and distributed denial of service (DDoS) attacks.

We analyze business activities with the aim of detecting suspicious behavior as soon as possible to avoid possible fraud and loss of funds at the hands of bad actors.

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3.3 To comply with legal and regulatory requirements

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With respect to the privacy and security of personal information, we will use the information in accordance with our legal obligations, government requests, and reasonable user-generated inquiries. In cases where it is strictly necessary, such as to protect the vital interests of Users or other natural persons, to fulfill the purpose of public interest, to pursue our reasonable interests (but not to harm the interests of Users), we may process your personal information without your consent. Except in the situations indicated in this Privacy Policy or the TUPs, we will not disclose or provide your personal information to third parties without a review of our legal team and / or the prior consent of the User.

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3.4 For measurement, research and development purposes

We actively measure and analyze data to understand how you use and interact with the EtradeDirect Services. Our operations teams conduct this review activity to continually improve the performance of our Platforms and resolve issues with the user experience. In addition, we use such information to personalize, measure and improve the EtradeDirect Services and the content and design of our websites and applications, and to develop new services.

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We continually monitor activity information within our systems and our communications with users to quickly find and fix problems.

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3.5 To communicate with you

We use the personal information collected, such as your phone number or email address, to interact with you directly when providing customer support on a ticket or to keep you informed about logins, transactions, account security and other aspects. Without collecting and processing your personal information to confirm each communication, we will not be able to respond to your submitted requests, questions and inquiries. All direct communications are properly stored at EtradeDirect or EtradeDirect's designated service provider, to be reviewed for accuracy, to be kept as evidence, or to be used to comply with other legal or contractual obligations.

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3.6 To enforce our TUP and other agreements

The information collected is also used to continuously and actively enforce our TUP and other agreements with our Users, including, but not limited to, reviewing, investigating and preventing any potentially prohibited or illegal activities that may violate the above provisions, or disclose the relevant information to a third party in accordance with the same.

EtradeDirect reserves the right to suspend or terminate the provision of any EtradeDirect Service to any User found to be involved in activities that violate our TUP and other agreements with our Users.

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3.7 To facilitate corporate acquisitions, mergers or transactions

We may process any information related to your EtradeDirect account and the use of EtradeDirect services as necessary in the context of corporate acquisitions, mergers or other corporate transactions.

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3.8 For marketing and advertising

We may share your personal information with our marketing partners for the purposes of targeting, modeling and / or analysis, as well as marketing and advertising.

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3.9 For refunds

We may share the information collected, including but not limited to your Identifying Information and Transaction Information, with your sender for the purpose of obtaining refunds and other benefits.

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3.10 For any other purpose

We may disclose your personal information for any other purpose that you consent to.

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4. MARKETING

If we think you may like the specific EtradeDirect Services or the products and services of our partners, we hope to keep you informed about those products or services.

If you agree to receive the above marketing information, you can choose to receive it at any time in the future.

You have the right to ask us at any time to stop communicating with you for marketing purposes or to send you relevant information. If you do not wish to be contacted for marketing purposes in the future, please click the unsubscribe link at the bottom of the marketing email and submit your request to unsubscribe.

5. HOW WE STORE AND PROTECT USER DATA

EtradeDirect has kept your personal information secure using secure, fault-tolerant storage with industry standard encryption and implemented a number of security measures to ensure that your information is not lost, abused or altered, including but not limited to:

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5.1 Physical measurements

Materials containing your personal information will be stored in a locked place.

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5.2 Electronic measurements

Computer data containing your personal information will be stored on computer systems and storage media that are subject to strict login restrictions.

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5.3 Management measures

Only authorized employees can come into contact with your personal information and those employees must comply with our internal rules of confidentiality for personal data. We have also imposed strict controls on physical access to buildings and archives.

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5.4 Technical measures

Encryption technology such as PCI Scanning and Secured Sockets Layered Encryption can be used to transmit and store your personal information. We use various general security technologies and support management systems available today to minimize the risks that your information may be disclosed, damaged, misused, accessed without authorization, disclosed without authorization, or altered.

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5.5 Other measures

Our web server is protected by the "firewall".

Please note that it is impossible to guarantee 100% information security. As such, we ask that you understand your responsibility to independently take security precautions to protect your own personal information. You agree that we will not be liable for any information leaks and other losses not caused by our intent or gross negligence, including but not limited to hacker attacks, power interruptions, or unavoidable technical failures, to the maximum extent permitted by law.

If you suspect that your personal information has been compromised, especially your account and / or password information, lock your EtradeDirect account and immediately contact EtradeDirect's customer service team at etradedirect@actius.mx

Unless otherwise provided by law or the TUP, you agree that we have the right, but not the obligation, to retain all personal information collected for the duration of your Etradedirect account for a further 5 years after the account is closed. .

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6. TRANSFERS OF PERSONAL INFORMATION

You understand that we have the right to have all or part of the personal information collected transferred or stored in other countries or regions other than your country of nationality, your country of residence or the country where the server is located, without your specific consent. , in the following circumstances:

6.1 if it is necessary to protect, process, analyze, reasonably use personal information;

6.2 if necessary to enforce the TUPs and other agreements with our Users;

6.3 if necessary for the public interest;

6.4 if necessary to establish, exercise or defend our rights, our partners or other Users;

6.5 other circumstances required by law or government orders.

7. COOKIES

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7.1 What are cookies?

Cookies are small amounts of data that are sent to your browser and stored on your computer's hard drive to collect standard Internet log information and information on visitor behavior. When you visit EtradeDirect, we may collect information about you automatically through cookies or similar technologies.

For more information, visit: www.allaboutcookies.org

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7.2 How do we use cookies?

We use cookies in a number of ways to make your experience on our Platforms more enjoyable, including but not limited to the following:

a. to keep it registered;

B. to record your habits and preferences when browsing EtradeDirect;

C. to record our performance and verify the effectiveness of online advertising through Google Stats with cookies.

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7.3 What types of cookies do we use?

We use different types of cookies, including but not limited to:

a. Functional cookies

We use such cookies to help us identify you and remember your previous preferences and settings, which may include your device, your operating system, your preferred language, your location, and other session data. We use a combination of own and third party cookies.

B. Marketing cookies

We use these cookies to collect information about your visit to EtradeDirect, the content you view, the links you follow, and other information about your browsers, devices, your IP addresses and referrer URLs. Sometimes we share certain parts of the information collected with third parties for marketing purposes. We may also share online data collected through cookies with our marketing partners. This means that when you visit another website, you may also be shown advertisements based on your browsing patterns on EtradeDirect.

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7.4 How to manage cookies?

Most browsers are preset to accept cookies. You can adjust your browser settings to prevent cookies or to notify you as soon as cookies are loaded. However, stopping all cookies may mean that you cannot access or use some EtradeDirect features.

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8. DATA PROTECTION RIGHTS YOU ENJOY

We hope to ensure that you are fully aware of the data protection rights that you enjoy. Unless otherwise required by law or government orders, each User has the following rights:

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8.1 Right of access

You have the right to access or obtain copies of your personal information. We may charge a reasonable fee for providing the access service.

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8.2 Right of rectification

You have the right to correct your personal information that you consider inaccurate. You also have the right to ask us to complete personal information that you consider incomplete within a reasonable limit.

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8.3 Right to erasure (right to be forgotten)

You have the right to request the deletion of your personal data in certain circumstances.

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8.4 Right to restriction of processing

In certain circumstances, as required by law or as we specifically recall, you have the right to request that we restrict the processing of your personal information; however, you understand that such restriction of processing may prevent us from providing you with some of the EtradeDirect Services.

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8.5 Right to object

In certain circumstances, as required by law or as we specifically recall, you have the right to object to the processing of your personal information; however, you understand that such objection to processing may prevent us from providing you with some of the EtradeDirect Services.

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8.6 Right to data portability

Under certain circumstances, as required by law or as we specifically recall, you have the right to request that we transmit the personal information we collect to another agency, or directly to you. We may charge a reasonable fee for providing the streaming service.

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9. PRIVACY POLICIES OF OTHER WEBSITES

9.1 Privacy policies of websites that do not belong to EtradeDirect

If you visit other third-party platforms or partner websites, applications through the links on EtradeDirect, you must accept and comply with their separate and independent privacy policies. We are not responsible for the content or activities in it.

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9.2 Etradedirect privacy policies

This Privacy Policy applies to all platforms, websites and departments of EtradeDirect.com and the EtradeDirect ecosystem. If you visit any link to any EtradeDirect sub-platform, you must accept and comply with the separate and independent privacy policies of those sub-platforms. If the privacy policy of any sub-platform conflicts with this Privacy Policy, the privacy policy of that sub-platform will prevail.

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10. CHANGES TO THIS PRIVACY POLICY

From time to time, EtradeDirect may revise this Privacy Policy to reflect changes in the law or in our personal data collection, processing and use practices. Changes to this Privacy Policy will be announced by posting at https://www.etradedirect.com/en/privacy. You should periodically review the Privacy Policy and pay attention to its revisions. If you do not agree with the revised content, you must immediately stop accessing EtradeDirect. When an updated version of the Privacy Policy is published, your continued access to EtradeDirect means that you accept the updated content and agree to comply with the updated Privacy Policy.

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11. CONTACT US

We are committed to respecting the freedoms and rights of all our EtradeDirect users. If you have any questions or concerns regarding this Privacy Policy, or if you wish to submit a data protection request, please contact us at our technical support email etradedirect@actius.mx

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© EtradeDirect 2021 - Mexico. All rights reserved.

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