Privacy Policy Last updated: 24/02/2024

We / We”, “Us” or “Our are dedicated to safeguarding your Personal Data and protecting your privacy.

This Privacy Policy has been designed to inform you about how We manage, collect, store, and use the information you provide in connection with the website (the “Website”).

We will adhere to the following principles:

• To be transparent in respect of the collection and processing of Personal Data about you:

We prioritize ensuring that you are always fully informed, enabling you to make informed choices regarding the use of your Personal Data on our Website or when initiating trade with a third-party trading platform. To achieve this, we employ a range of strategies and methods designed to offer you pertinent details on how your Personal Data is processed, ensuring this information is delivered accurately and timely.

Additionally, if We determine that you need to be provided with specific information, We will ensure it is delivered to you at the appropriate time and place.

We are also available to answer any questions you may have and to provide you with any clarification you require, subject to legal limitations. For this purpose, you can reach Us by sending an email to the following address: support@

• To process Personal Data about you solely for the purposes outlined in the Policy:

The purposes for which We may process Personal Data about you include, among others, making the Website available to you andprovide a connection to third-party trading platforms (the “Services”), enhancing your experience on the Website, improving our Services (including the Website), safeguarding our rights and interests, and conducting business and administrative activities that support our Service delivery to users of the Website, while also adhering to legal and regulatory obligations.

Additionally, we process your Personal Data to better understand your individual needs and preferences.

• We are committed to respecting your rights regarding your Personal Data:

We dedicate substantial resources to enable you to exercise your rights as a data subject. You are welcome to contact us at any time to review, amend, erase, restrict the use of, or transfer your Personal Data to yourself or a third party. We will comply with your requests in accordance with the law.

• Securing your Personal Data:

While we cannot guarantee absolute security for your Personal Data, we assure you that we utilize and will continue to utilize a comprehensive range of measures to secure your Personal Data.

Our Comprehensive Privacy Policy

1. Scope of Policy

This Policy outlines the types of Personal Data the Company collects about individuals, how it is collected, used, shared with third parties, secured, processed, and more.

In this Policy, “Personal Data” refers to any information related to an identified or identifiable natural person. An identifiable natural person is someone who can be identified, directly or indirectly, in conjunction with additional information that we possess or have access to.

In this Policy, the “processing” of Personal Data refers to any operation or set of operations performed on Personal Data, including its collection, recording, organization, structuring,storage, modification, retrieval, consultation, use, disclosure by transmission, dissemination, alignment, combination, restriction, erasure, or destruction of Personal Data.

Our Services are designed for a general audience and are not targeted at individuals under 18 years old. We do not knowingly collect or request information from anyone under 18 or knowingly permit such individuals to use our Services. If we become aware that we have collected information from a child, we will take reasonable measures to delete that information promptly.

2. When Do We Collect Personal Data About You?

We gather Personal Data about you whenever you utilize the Services, interact with our service channels, and visit the Website. Sometimes, you will actively provide us with Personal Data, while other times, we will collect Personal Data by analyzing your use of our Services and/or service channels or receiving your data from our third-party partners.

3. No Obligation To Provide Personal Data To The Company And Its Implications

You are not required to provide us with any Personal Data. However, in certain instances, not providing such Personal Data will hinder us from delivering the Services to you, restrict your access to the Website, and/or cause malfunctions in the Services and the Website.

4. What Types of Personal Data Do We Collect? Personal Data We Collect During Each Visit to the Website:

This information includes online activity logs, traffic data (including, but not limited to, IP address, access time, access date, web and mobile pages visited, language used, software crash reports, and browser type), and information about the device you used. Some of this information may not identify you personally and therefore does not constitute Personal Data.

Personal Data We Receive From You: Any Personal Data you voluntarily provide to us when engaging with a third-party trading platform through Vorotok App.

Personal Data You specifically provide for submission to third-parties platforms in order to trade: This includes your full name, telephone number, and email address.

5. The Purposes of The Processing Of Personal Data And Their Legal Basis

Vorotok App processes your Personal Data for one or more of the purposes outlined in this section and according to the appropriate legal basis.

Vorotok App will not process Personal Data about you unless there is a legal basis for such processing. The legal bases according to which Vorotok App may process Personal Data about you are as follows:

• You have given consent to the processing of your Personal Data for one or more specific purposes. This refers to cases where you specifically provide your details through the Website, so that we may submit them to third-party trading platforms.
• Processing is necessary for the purposes of the legitimate interests pursued by Vorotok App or by a third party. For example, for the purpose of enhancing our services, or for the exercise or defense of legal claims.
• Processing is necessary for compliance with a legal obligation to which Vorotok App is subject.

Should you require additional details on how the processing of your Personal Data aligns with the legitimate interests of our Company or an external party, please feel free to reach out to us via email at any moment.

Below, we present a summary of the reasons we might process your Personal Data, along with the legal grounds for such activities:

	Purpose	Legal Basis
1	To share your information with third parties upon your request for digital and trading engagements We may gather your Personal Data to share it with third parties, but only if you specifically request this.	You have given consent for your Personal Data to be processed for one or more specific purposes.
2	To address your inquiries, requests, and/or complaints Processing your Personal Data is necessary to respond to any queries you may have regarding your use of the Services.	Processing is necessary for the legitimate interests pursued by the Company or by a third party.
3	To comply with legal obligations or judicial/administrative orders We handle your Personal Data to meet our legal responsibilities.	Processing is necessary for compliance with a legal obligation applicable to the Company.
4	To enhance Our Services We may utilize your Personal Data to improve our offerings. This includes processing crash logs or other malfunction reports related to our Services.	Processing is necessary for the legitimate interests pursued by the Company or by a third party.
5	To prevent fraud and misuse of Our Services	Processing is necessary for the legitimate interests pursued by the Company or by a third party.
6	To carry out and sustain various activities supporting Our Services Such activities encompass back-office operations, business development tasks, strategic decision-making, and oversight mechanisms, among others.	Processing is essential for the legitimate interests pursued by the Company or by a third party.
7	For conducting analysis, including statistical evaluations We employ a variety of analytical methods (including statistical ones) to make informed decisions on various matters.	Processing is essential for the legitimate interests pursued by the Company or by a third party.
8	To safeguard our and third parties' interests, rights, and assets, including the initiation, exercise, or defense of legal claims We may process your Personal Data to protect our interests, rights, and assets, or those of third parties, in accordance with any law, regulation, or agreement, including any of our terms and conditions and policies.	Processing is essential for the legitimate interests pursued by the Company or by a third party.

6. Transfer Of Personal Data To Third Parties

The Company may also disclose your Personal Data to third parties that provide services to Us, such as storage and hosting providers, IP address information, user experience analysis, research, as well as analytical, technical, and diagnostic services.

Additionally, you may request that We submit specific Personal Data about you to third-party trading platforms. In such instances, we will share the Personal Data you provide to Us for this purpose with these third parties, and their use of your Personal Data will be governed by their own privacy policies. We may share your Personal Data with multiple third-party trading platforms.

The Company may also share your Personal Data with its affiliated entities and business partners, which provide resources that enable the Company to enhance and improve the services and products it offers to its users.

The Company may disclose your Personal Data to governmental, local, official, and regulatory authorities, as well as if such disclosure is necessary to protect Our and third parties' interests, rights, and assets, including the initiation, exercise, or defense of legal claims.

Furthermore, We may disclose your Personal Data to potential purchasers or investors of, or lenders to, the Company and/or any company within the group of companies to which the Company belongs, or in the event of any similar transaction (including the sale of assets of the Company and/or any company within the group of companies to which the Company belongs), and/or in connection with any merger, reorganization, consolidation, or bankruptcy of the Company and/or any company within the group of companies to which the Company belongs.

7. Cookies and Third-Party Services

We may utilize certain third-party services, such as analytics companies or companies delivering advertisements on our Website, which may also use cookies or other technologies. These practices and providers are subject to their own policies.

A cookie (which is a small text file) is installed on the device through which you visit or access the Website. The cookies allow for the collection of information about you and your behavior, in order toenhance your user experience by remembering your preferences and settings, and by customizing and offering you products and services that might interest you. Additionally, cookies can be used to gather statistics and perform analytics.

We may utilize session cookies, which are temporarily downloaded to your device and last until you close your web browser. We may also use persistent cookies, which remain on your device after you stop browsing the Website and help remember you as a returning visitor when you revisit the Website.

Types of cookies:

The cookies we use are categorized according to their functionality, as follows:

Type of Cookie	Purpose	Additional Information
Strictly Necessary Cookies	These cookies are essential to enable you to navigate the Website and utilize the features you have requested. They are employed to provide you with our content, products, and services that you have asked for. These cookies are crucial to assist your device in downloading or streaming information, allowing you to move around the Website, use its features, and return to pages you have previously visited.	These cookies collect personal data about you, such as your username and last login date, and identify you as being logged into the Website. These cookies are automatically deleted when you close your web browser (session cookies).
Functionality Cookies	These cookies help recognize you when you revisit the Website and enable Us to remember your preferences and selections.	These cookies persist even after you close your web browser, lasting until their set expiration time.
Performance Cookies	These cookies are utilized to provide aggregated statistics regarding the Website's performance, allowing Us to test and enhance its functionality for a superior user experience. They also enable Us to perform analytical tasks on the Website.	These cookies gather anonymized data that is not associated with any identified or identifiable individual. The validity of these cookies varies; some are deleted when you close your browser, while others have an indefinite validity period.

Blocking and Removal of Cookies

You can modify your browser settings to block and remove some or all cookies. Below are links to instructions for some of the most popular web browsers:

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please be aware that disabling these settings may affect the performance and functionality of the Website's features.

ONLINE TRACKING NOTICE

CURRENTLY, THIS SERVICE DOES NOT SUPPORT DO-NOT-TRACK SIGNALS.

8. Retention Of Personal Data About You

The Company will retain your Personal Data for as long as necessary to fulfill the processing purposes outlined in this Policy, or for an extended period as mandated by relevant legislation, regulations, policies, and orders.

We will share your information with third-party trading platforms for a 12-month period and, subject to your consent, will continue to do so for an additional 12 months.

To ensure that Personal Data is not kept longer than necessary, we periodically review the data we hold to determine if any can be safely deleted.

9. Transfers of Personal Data To A Third Country Or An International Organization

Your Personal Data may be transferred to countries outside your jurisdiction or to international organizations. In such cases, the Company will implement appropriate safeguards to ensure your data is protected and that you have enforceable data subject rights and effective legal remedies.

If you are a resident of the EEA (European Economic Area), please note that these protections will be provided if any of the following conditions are met:

• The transfer is directed to a third country or an international organization that the EU Commission has determined offers an adequate level of protection for Personal Data transferred to it, as per Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR").
• The transfer is made in accordance with a legally binding and enforceable instrument between public authorities or bodies, as stipulated in Article 46(2)(a) of the GDPR; or
• The transfer complies with standard data protection clauses adopted by the EU Commission pursuant to Article 46(2)(c) of the GDPR. These clauses adopted by the EU Commission can be accessed at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

You may request detailed information about the safeguards employed by the Company to protect your Personal Data when transferred to a third country or an international organization by sending an email to the following address: support@

10. Protection Of Your Personal Data

We employ appropriate technical and organizational measures to ensure a suitable level of security for Personal Data, taking into account the risks presented by processing, particularly from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to Personal Data transmitted, stored, or otherwise processed.

While we strive for error-free performance in protecting your Personal Data, we cannot guarantee it, nor do we represent that there will be no errors. We will not be liable for any indirect, incidental, consequential, or punitive damages related to the use or release of your Personal Data, including but not limited to, disclosure due to transmission errors, unauthorized third-party access, or other causes beyond our reasonable control.

We may be compelled, due to legal or other obligations outside our control, to transfer your Personal Data to third parties,such as public authorities. In these cases, our control over the protection level provided to your Personal Data by these third parties is limited.

The transfer of Personal Data via the internet cannot be entirely secure. Therefore, Vorotok App cannot guarantee the protection of your Personal Data when it is transmitted over the internet to us.

11. Links To Websites of Third Parties

Our Website may include links to third-party websites and/or applications. Vorotok App does not control these websites and applications, nor the collection and/or processing of your Personal Data by them, and we are not accountable for their privacy and data protection practices and activities. This Policy does not apply to any actions conducted through such websites and/or applications.

Whenever you access these third-party websites and/or applications, we advise that you thoroughly review their privacy policies before using their services and disclosing any of your Personal Data.

13. Your Rights Regarding Your Personal Data

Generally, you have the right to request that we confirm whether we are collecting your Personal Data, to review such data, to rectify its content if necessary, and to erase Personal Data that we no longer need. You may also restrict your consent to certain processing of your Personal Information.

If you are an EEA resident, please read this section below:

You are entitled to the following rights regarding your Personal Data. To exercise these rights, you may send a request to the following email address:

Right of access

You have the right to receive confirmation from Vorotok App as to whether your Personal Data is being processed, and, if so, access to your Personal Data and the following information:information: (1) the purposes of the processing; (2) the categories of Personal Data involved; (3) the recipients or categories of recipients to whom the Personal Data has been or will be disclosed, particularly those in third countries outside the European Economic Area (EEA) or international organizations; (4) if possible, the anticipated duration for which the Personal Data will be stored, or, if not feasible, the criteria used to determine that period; (5) the existence of the right to request from the Company rectification or erasure of Personal Data, or restriction of processing of Personal Data about you, or to object to such processing; (6) the right to lodge a complaint with a supervisory authority; (7) if the Personal Data is not collected from you, any available information about its source; (8) the existence of profiling; and (9) if Personal Data is transferred to a third country outside the EEA or to an international organization, the appropriate safeguards related to the transfer.

The Company shall provide a copy of the Personal Data undergoing processing and may charge a reasonable fee for any additional copies requested by you. If you make the request electronically, and unless otherwise requested by you, the information shall be provided in a commonly used electronic format.

The right to obtain a copy of the Personal Data shall not adversely affect the rights and freedoms of others. Therefore, if the request impacts the rights and freedoms of others, the Company may not fulfill your request or may do so in a limited manner.

Right to rectification

You have the right to obtain from the Company the rectification of inaccurate Personal Data about you. Considering the purposes of the processing, you have the right for incomplete Personal Data about you to be completed, including by providing a supplementary statement.

Right to erasure

the following grounds apply: (a) the Personal Data is no longer necessary for the purpose for which it was collected or otherwise processed; (b) you withdraw your consent on which the processing is based and there is no other legal ground for the processing; (c) you object at any time, on grounds relating to your particular situation, to the processing of Personal Data about you that is based on the legitimate interests pursued by Us or by a third party, and there are no overriding legitimate grounds for the processing; (d) you object to the processing of Personal Data about you for direct marketing purposes; (e) thePersonal Data has been unlawfully processed; or (f) the Personal Data concerning you must be erased to comply with a legal obligation in European Union or Member State law to which the Company is subject.

This right is not applicable to the extent that the processing is necessary (a) for compliance with a legal obligation that mandates processing by European Union or Member State law to which the Company is subject; or (b) for the establishment, exercise, or defense of legal claims.

Right of restriction of processing

You have the right to request the Company to restrict the processing of Personal Data concerning you if one of the following conditions is met: (a) you contest the accuracy of the Personal Data, allowing the Company time to verify its accuracy; (b) the processing is unlawful and you oppose the erasure of the Personal Data, requesting instead the restriction of its use; (c) the Company no longer requires the Personal Data for processing purposes, but you need it for the establishment, exercise, or defense of legal claims; (d) if the processing of Personal Data is necessary for the legitimate interests pursued by the Company or by a third party, unless we demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims; or (e) if the Personal Data is processed for direct marketing purposes, including profiling, to the extent it is related to such direct marketing.

If the processing of Personal Data has been restricted following your request, such Personal Data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.

Right to Data Portability

You possess the right to obtain your Personal Data, which you've supplied to the Company, in a structured, widely used, and machine-readable format. You also have the right to transfer that data to another entity if the processing is based on your consent or a contract you're part of, and if the processing is automated.

When exercising your data portability right, you can have your Personal Data transferred directly from the Company to another organization, provided it is technically feasible. This right does not influence either your or the Company's rights concerning data deletion. Additionally, the exercise of this right must not adversely impact the rights and freedoms of others.

Right to Withdraw Consent

You may withdraw your consent for us to process your Personal Data at any time. This will not affect the legality of any processing performed before your withdrawal.

Right to Object

You are entitled to object to the processing of your Personal Data at any point, especially if it pertains to your specific situation and the processing is justified by the legitimate interests of the Company or a third party. This includes any profiling based on those interests. Upon your objection, we will cease processing your Personal Data unless we can present compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.

You also have the right to object to the processing of your Personal Data for direct marketing purposes at any time, including any related profiling.

Right to Lodge a Complaint with a Supervisory Authority

You have the right to file a complaint with a supervisory authority established by a Member State to safeguard the fundamental rights and freedoms of individuals regarding the processing of Personal Data within the European Union.

Your rights concerning your Personal Data as described in this section 13 may be restricted by European Union or Member State law to which the Company is subject.

We will provide you with the requested information in accordance with your rights outlined in this section 13 without undue delay and in any event within one month of receiving the request. This period may be extended by an additional two months if necessary, considering the complexity and number of requests. We will inform you of any such extension within one month of receiving your request, along with the reasons for the delay.

The information requested in accordance with your rights outlined in this section 13 shall be provided free of charge, unless otherwise stated in this section 13. Where requests are manifestlyunfounded or excessive, particularly due to their repetitive nature, we may either (a) charge a reasonable fee, considering the administrative costs involved in providing the information or communication or taking the requested action; or (b) refuse to comply with the request.

The Company may require you to provide additional information necessary to verify your identity to process your request according to your rights outlined in this section 13, if we have reasonable doubts about the identity of the person making the request.

12. Changes To This Policy

We may periodically revise the terms of this Policy. Whenever we make changes to this Policy, we will notify you by publishing the updated Policy on the Website. Additionally, when we make significant amendments, we will make efforts to inform you through means of communication we deem appropriate and by posting a notice about the changes on the Website. Unless stated otherwise, all amendments will take effect upon publication of the updated Policy on our Website.