1 Table of Contents

2 Scope and changes

3 What personal data do we collect?

3.1 What is personal data?

3.2 Personal data that you provide when using our services or when ordering a trading account

3.3 Personal data that we collect automatically when using our services or when ordering a trading account

3.4 Personal data that we collect using cookies or similar technologies

3.5 Recording of telephone conversations

3.6 Data and communications from service providers with whom Agora Trading System Limited collaborates

3.7 Personal data from other sources

4 How do we use your personal information?

4.1 Use for the fulfillment of our contractual relationships

4.2 Use to pursue our legitimate interests

5 Your choices regarding the use of your personal information by us

5.1 Use to pursue our legitimate interests

5.2 Advertising

5.3 Newsletter

5.4 Loginmechanismen

6 Information, control and correction of your personal data

7 Transfer of your personal data

7.1 Service partners and brokers/banks

7.2 Law enforcement agencies, third parties in court proceedings, or legally authorized third parties

7.3 Change of ownership

8 Retention periods and locations

8.1 Retention periods

8.2 Retention location

9 Responsible for data protection

10 Further important information about privacy

10.1 Unwanted and threatening emails

10.2 Communication tools

10.3 Privacy of children

10.4 Privacy rules of third parties

2 Scope and changes

This Privacy Policy applies to all websites, applications, services or tools (collectively referred to as "Services") that are controlled by Agora Trading System Limited Ltd. and their partners (hereinafter referred to as "AGORA direct" or "we"), regardless of how they are accessed or used by you. Partners of Agora Trading System Limited are always informed on our website under About Us.

The constant development of laws and regulations make it necessary to adapt and supplement this privacy statement. Therefore, please always pay attention to our website, we always try to inform you in good time about it under "My AGORA" or via e-mail. Although it is in our best intention, we cannot we cannot by its very nature give any guarantee for this.

3 What personal data do we collect?

3.1 What is personal data?

Personal data is information about a specific or identifiable natural person. An identifiable natural person is a person who identifies directly or indirectly through attribution features such as account numbers, database identification numbers, or specific information that is an expression of their physical, physiological, mental, economic, cultural, or social identity.

Anonymous or aggregated data are not regarded as personal data, which therefore can no longer be used to identify a determinable natural person.

In order to be able to use our services, Agora Trading System Limited will collect personal data from you. Whenever data is referred to below, we refer to personal data.

3.2 Personal data that you provide when using our services or when ordering a trading account

3.3 Personal data that we collect automatically when using our services or when ordering a trading account

The pages of Agora Trading System Limited Limited can be visited by anyone without providing any personal data. Despite of this, the Agora Trading System Limited Limited is collecting IP Address, time of access, amount of data, referer, and browser that has been used for statistics and for improving our systems. Should it be the unlikely case that from these data conclusions can be drawn in regard to your person these will be treated highly confidential.

3.4 Personal data that we collect using cookies or similar technologies

Agora Trading System Limited can use text information files, also called cookies, on its website. This serves to make offer and achievement more individually available. These text information files are sent from an Internet server to the customer's home computer to identify this computer for time during its visit. For better transparency, computers can be set to inform about the placement of these so-called cookies.

3.5 Recording of telephone conversations

As an introducing broker, we are legally obliged to record telephone conversations with customers and to store them in accordance with legal regulations. If you do not want a recording, please use another communication channel.

3.6 Data and communications from service providers with whom Agora Trading System Limited collaborates

Service providers we work with can, according to the mailing authority you give us, provide us with communications and information.

3.7 Personal data from other sources

4 How do we use your personal information?

Agora Trading System Limited continually strives to ensure the strict confidentiality of personal information. All employees, any representatives or other vicarious agents, the shareholders of Agora Trading System Limited, as well as all contract and cooperation partners are in principle obliged to secrecy.

Agora Trading System Limited respects and protects the personal data of customers and users of the Agora Trading System Limited website. Personal data will only be collected and processed if voluntarily provided by the user / customer of the Agora Trading System Limited website. These data will then be used only for the purpose for which they are intended for input or for Agora Trading System Limited to assume that they should be intended for a particular purpose.

4.1 Use for the fulfillment of our contractual relationships

Data that is collected is used to provide the services offered by Agora Trading System Limited and are limited in scope and nature of these services. In the course of issuing an Account Opening Order, Agora Trading System Limited is required by law to collect and process personal information. In order for Agora Trading System Limited to be able to perform the services offered, Agora Trading System Limited uses other contractual service partners. However, these contractual partners are only aware of the customer data disclosed to Agora Trading System Limited, insofar as these are necessary for the performance of the services. The disclosure of customer data to third parties is prohibited to the service partners by contract and according to statutory provisions, as well as the further use of the data outside the contractual relationship with Agora Trading System Limited. Agora Trading System Limited is always up-to-date on its website with the current contractual service providers.

4.2 Use to pursue our legitimate interests

We will use your personal information to pursue our legitimate interests, unless your fundamental rights and freedoms prevail.

5 Your choices regarding the use of your personal information by us

5.1 Notification settings

Under "My AGORA" you can make various settings to determine how we can send you information, such as general information about your account, annual account statements, margin requirements, etc.

5.2 Advertising

If you do not want to get targeted advertising, if you do not want to be tracked on social networks, please check with your browser manufacturer to see how certain privacy settings work in your browser. Keywords for this include cookie usage and storage, browser tracking, anonymous mode.

5.3 Newsletter

For the continuous supply of information, newsletters can be obtained. Additionally, user/customer provides an e-mail address, and obligatory name, first name and date of birth. The customer assures that these data are not wrong or third party data. By entering this data, the customer agrees to receive newsletters. Agora Trading System Limited is not obliged to send regular newsletters. Agora Trading System Limited is expressly allowed to contact the customer in writing, by telephone or by e-mail to inform about products and services. At any time, customers may revoke the authorization in writing to datacontroller@agora-direct.com or by phone at: +49 (0) 309 789 59 75 - 0 [English number for UK website). For subscriptions, the agreed notice periods shall apply. All data collected in this context will under no circumstances be disclosed to third parties and otherwise treated as described above. These data may be stored by Agora Trading System Limited and evaluated for statistical purposes.

5.4 Loginmechanismen

We use and store cookies to verify login and login time. This cookie contains your session. After completing your login, this cookie will be deleted.

6 Information, control and correction of your personal data

Users/customers, who request which of their data has been stored and/or processed by Agora Trading System Limited Limited, are entitled to request information about this. If this is the case, the request needs to be as detailed as possible in written form and with appropriate remarks with appropriate evidence exclusively to:

German Website: Agora Trading System Limited – Data protection officer
PO Box 304235
10757 Berlin Germany
UK Website: Agora Trading System Limited – Data protection officer
5 Prospect Place Millennium Way
Pride Park Derby DE24 8HG
United Kingdom

Requests for information about data by e-mail or fax can only, due to a lack of clear identification, be requested by post and in written form. Agora Trading System Limited may and will, in case of doubt about the identity of the requester, require further identification information.

7 Transfer of your personal data

7.1 Service partners and brokers/banks

We are an Introducing Broker, which means you ask us to open an account with another service provider. We shall keep clients/users updated on our website, about who is our current contractual service provider. When ordering an account application, we need your above mentioned data in order in order to open an account with this service provider.

7.2 Law enforcement agencies, third parties in court proceedings, or legally authorized third parties

In order to comply with legal regulations, in order to enforce our terms and conditions, as well as the terms and conditions of our service partners, in order to defend legal claims, we may pass data to the above authorities or third parties.

If legally authorized third parties involved in a lawsuit provide us with a legal evidence, with a court-, or with an equivalent legal act, or if we believe in good faith that disclosure of the data is necessary in order to prevent an imminent threat to life and limb, or in order to prevent financial loss, or to report a suspected wrongful act, we may also share information.

7.3 Change of ownership

In the event of a merger, sale or other equivalent event, we may share information with this company in accordance with our privacy policy. If such an event occurs, we will require the new entity to comply with this Privacy Policy.

8 Retention periods and locations

8.1 Retention periods

Data is kept in accordance with legal deadlines and regulations. Data containing a complaint potential will be retained for the period in which a complaint or legal action against us is possible.

8.2 Retention location

All personal data is being stored, processed, and accessed within the EU and UK. Data will never leave the scope of our servers or if necessary the scope of the servers of our service partners.

9 Responsible for data protection

Agora Trading System Limited Limited has appointed a Data Protection Officer.
Mr Markus Nowatzki, Schwäbische Str. 5, 10781 Berlin, Germany

10 Further important information about privacy

10.1 Unwanted and threatening emails

We do not tolerate misuse of our services. Unless expressly permitted, we do not tolerate any commercial use of our services.

Agora Trading System Limited does not send spam. Please report spam or fraudulent e-mail or SMS messages related to Agora Trading System Limited and forward them to datacontroller@agora-direct.com.

10.2 Communication tools

We may automatically scan messages sent through our messaging tools and check them for spam, viruses, phishing content or other malicious activity, unlawful or prohibited content, or for violations of our Terms and Conditions, this Privacy Policy or our other policies.

10.3 Privacy of children

Our websites are intended for the general public and not for children. We do not knowingly collect personal information from users who are considered to be children under their respective national laws.

10.4 Privacy rules of third parties

This Privacy Policy applies only to the use and disclosure of personal information that we collect from you in connection with the provision of our services. If you disclose your information to third parties or if you are directed to a third party website, its privacy policy applies to any personally identifiable information you provide to or collect from that third party.

Date: 01.01.2021