Appendix №4 to the Terms and Conditions of NBCGate Business

NBCGATE Privacy Policy

1. General Provisions.

This Privacy Policy governs the collection, processing and use by NBCGate ("Company" or "we", "us", "our", etc.) of your Personal Information that you provide to us when you access or use NBCGate services on our websites, including https://nbcgate.com/ and/or other sites including sites hosted at other domains (collectively, the Site and/or Web site) and mobile applications of the Company and related services provided by the Company through the Site and/or related mobile applications as provided in our Agreement. Personal Information" refers to information that identifies an individual, such as name, address, email address, phone number, financial information, and banking information. "Personal Information" does not include anonymous and/or aggregated data that does not identify a specific user.

The company is committed to protecting and respecting your privacy. The purpose of this Privacy Policy is to describe:

- The types of Personal Information we collect and how it may be used;

- How and why we may disclose your Personal Information to third parties;

- Transfers of your Personal Information;

- Your right to access, correct, update and delete your Personal Information;

- The security measures we use to protect and prevent the loss, misuse or alteration of Personal Information;

- Company's retention of your Personal Information;

This Privacy Policy also covers some of the basics of our use of cookies, but please also refer to our Cookie Policy for more information;

We control the way We collect your Personal Information and determine the purposes for which We use Personal Information. We are a "data controller" within the meaning of the General Data Protection Regulation (EU) 2016/679 (hereinafter referred to as "GDPR") and other applicable European data protection laws.

2. Collection and use of personal information

A. Personal Information We Collect

We collect the following Personal Information:

- Contact information, such as first name, last name, phone number, home address, and email address.

- Account information, such as your username and password.

- Financial information such as bank account numbers, bank statements, trading activity and history, fees charged, etc. Д.

- Identity verification information, such as images of your government-issued identification card, passport, national ID card, driver's license, or other documents requested by our compliance department.

- Residence verification information, such as utility bill information or similar information.

Other information obtained through our KYC procedures, such as information about your financial condition and source of funds.

We also automatically collect certain computer, device, and browsing information when you access the Website or use the Services. This information is aggregated to provide statistics about the actions and browsing patterns of our users and does not personally identify individuals. This information may include:

Information about the computer or mobile device you use to access our Website and/or mobile applications, including hardware model, operating system and version, web browser you use, IP addresses and other device identifiers.

To collect, process and analyze information and personal data, we may use special services such as AppMetrica and others.

Website usage information, server log information, which may include (but is not limited to) your login details, date and time of visits, pages viewed, your IP address, time spent on our Website and the websites you visit immediately before and immediately after our Website.

Bandwidth download and upload speeds, the amount of free and used storage space on your device, and other statistics about your device.

We may automatically collect, store and otherwise process information about you even if you decline to complete an online application or registration form.

B. Use of Cookies and Similar Technologies

The website and mobile applications use cookies. Cookies are small text files that are placed on your computer by websites you visit. They are widely used to make sites work, or work more efficiently, and to provide information to site owners. Cookies are usually stored on your computer's hard drive. Our Website uses cookies to enable you to use the Website and/or mobile applications, Services we offer, and materials on the Website. Cookies are also used to distinguish you from other users of our Website. This helps us provide you with a good experience when you browse our Website and allows us to improve our Website and mobile applications. For more information about the cookies we use and the purposes for which we use them, see our Cookie Policy.

C. How We Use Your Personal Information

We may use your Personal Information to:

- Process your transactions. We will only process your Personal Information for the purposes for which it was provided to us.

- To comply with our legal or regulatory requirements;

- Confirm your identity in accordance with applicable laws and Company anti-money laundering policies, and comply with other law enforcement requests. We may also share your information with other financial institutions and tax authorities if such actions are required of us under any applicable law.

- Identify, investigate and prevent fraudulent transactions or unauthorized or illegal activities;

- Protect our rights and property;

- Personalize our Services.

- Analyze usage of the Website and mobile applications and improve them. Analyze and track data to determine the usefulness or popularity of certain content and better understand the online activity of our Website users;

- Helping us respond to your customer service inquiries and support needs, respond to your request or respond to your message;

- To contact you with questions related to the Services. The email address you provide may be used to communicate information and updates related to your use of the Services. We may also transmit from time to time technical, support or administrative notices, company news, updates, promotions and related information relating to similar products and services provided by the Company.

- Administer contests, promotions, surveys or other features, which will be described in more detail on the Website.

- Link, combine or merge Personal Information we collect from or about you with other Personal Information;

- To fulfill any other purpose or reason for which the Information was collected.

We do not conduct behavioral tracking of customer activities on our Website and/or mobile applications, nor do we allow third parties to collect data through our services and facilities. If you wish to stop receiving marketing communications from us, please contact us at support@nbcgate.com to opt-out.

3. Disclosure and transfer of Personal Information

We may disclose your Personal Information to third parties, legal and regulatory authorities and transfer your Personal Information as described below:

A. Disclosures to Third Parties

In processing your transactions, we may share some of your Personal Information with our third party service providers to assist in our business operations. Your information will not be sold, exchanged or shared with third parties without your consent, except to provide the Services or as required by law. By using the Website or Services, you consent to the disclosure of your Personal Information as described in this Privacy Policy. Non-personally identifiable visitor information may be provided to third parties for marketing, advertising or other purposes. Company's third party service providers are contractually obligated to protect and use such information only for the purpose for which it was disclosed, except as otherwise required or permitted by law. We ensure that such third parties will be bound by terms similar to those described in this Privacy Policy or those to which we are subject under applicable privacy laws.

В. Disclosure to Legal Authorities

We may disclose your Personal Information to law enforcement agencies, data protection authorities, government officials and other authorities when:

There is a compulsory subpoena, court order or other legal process to provide the information.

We believe that disclosure is necessary to prevent physical harm or financial loss.

Disclosure is necessary to report suspected illegal activity.

Disclosure is necessary to investigate violations of this Privacy Policy or any of our agreements with you.

С. International transfers of personal information

We store and process your Personal Information in data centers around the world, wherever Company facilities or service providers are located. Therefore, we may transfer your Personal Information between such data centers. Such transfers are in compliance with our legal and regulatory obligations and are made only through secure channels.

D. Other Circumstances for Disclosure of Personal Information

We may also disclose your Personal Information in the following circumstances:

- With your consent or on your behalf. Certain information you may share may be displayed publicly, such as your username and any content you post when you use interactive areas of our Website, mobile applications, such as our online forums;

- with our current or future parent companies, affiliates, subsidiaries and other companies under common control or ownership with us or our offices internationally. We ensure that listed parties will be bound by terms similar to those described in this Privacy Policy or those to which we are subject under applicable data protection laws;

- if sharing Personal Information is necessary to protect our rights and property, or the rights and property of the above listed current or future parents, affiliates, subsidiaries and other companies under common control or ownership with us;

4. External Websites

Occasionally, the Website and mobile applications may provide links or references to other websites ("External Websites") not controlled by the Company. We have no control over those External Websites or any content contained on them. You agree that we are not responsible in any way for External Websites linked to or from the Company Website, including but not limited to website content, policies, failures, promotions, products, services or activities and/or any loss, damage, disruption or problems caused by, relating to or arising from such sites. External websites have separate and independent privacy policies. We encourage you to review the policies, rules, terms and conditions of each site you visit. We are committed to protecting the integrity of our website and welcome any feedback about external website information provided on the Company's website.

5. Your rights in relation to your personal information

You may exercise all rights provided by law, as long as it does not conflict with legal requirements relating to money laundering and terrorist financing, our record-keeping obligations, etc. Д.

You have the following rights:

- The right to be informed that we process your Personal Information and what kind of data we process,

- the right to data portability. Under certain circumstances, you have the right to receive all of your Personal Information that we maintain in a machine-readable format;

- the right to object to the processing of your Personal Information.

- The right not to be subjected to automated decision-making, including profiling, as long as it does not interfere with the performance of the contract between you and us.

- The right to access your Personal Information and to have inaccurate and/or incorrect data corrected, updated and blocked;

- the right to withdraw your consent to the processing of your Personal Information;

- the right to have your Personal Information removed from our servers at your reasonable request (the right to be forgotten);

To exercise these rights, contact us at support@nbcgate.com

Within 40 days of receiving your written request, we will provide you with your Personal Information, including the purposes for which it was used and to whom it was disclosed in accordance with applicable law. We reserve the right to request additional information from you as may be necessary to properly respond to your request in accordance with applicable law, and you consent to our right to do so. In addition, if you wish to correct, update and block inaccurate and/or incorrect data, we have the right to request you to provide evidence of the accuracy of the data, such as official documents containing such data.

Please note that if we are unable to verify your identity through emails or by your application to the call center, or if there is reasonable doubt about your identity, we may ask you for proof of identity, including by appearing in person at our office. This is the only way we can avoid disclosing your Personal Information to someone who might identify you.

In some cases, we may not be able to change your Personal Information. In particular, this may include an event where your Personal Information has already been used during the execution of any agreement or transaction, or is listed in any official document, etc.

You have the right to withdraw your consent to the processing of personal information. You may also exercise your right to suppress and delete your Personal Information from our servers. Where permitted under Article 17 of the GDPR, we will delete your Personal Information that we process, except for those Personal Information that we are required to retain under the requirements set forth by applicable law.

Please note that if you exercise your right to withdraw your consent to the processing of Personal Information or your right to be forgotten, we will not be able to provide you with our products or services, and we obtain a special right to terminate all of our current agreements with you with the legal consequences of such termination, and you unconditionally acknowledge such right of us.

In order to withdraw your consent to the processing of personal data and/or to exercise your rights of oblivion, please contact us at: support@nbcgate.com. In addition, in this case, for security reasons, we may ask you to present proof of identity, including directly at our office.

6. Security of Personal Information

We use various security measures to ensure the privacy of your Personal Information and to protect your Personal Information from loss, theft, unauthorized access, misuse, alteration or destruction. These security measures include, but are not limited to, the following:

Password-protected directories and databases.

Secure Sockets Layered (SSL) technology to ensure full encryption and secure transmission of information over the Internet.

Limited access to hosting servers using 2FA and traffic encryption.

All financially sensitive and/or credit information is transmitted via SSL technology and encrypted into our database. Only authorized Company personnel are allowed access to your Personal Information, and those personnel are required to treat the information as strictly confidential. Security measures will be reviewed regularly in light of new and relevant legal and technical developments.

7. Retention of Personal Information.

We retain Personal Information for as long as necessary to fulfill the purposes described in this Privacy Policy, subject to our own legal and regulatory obligations. Consistent with our record-keeping obligations, we will retain the record and other Personal Information for at least five years after termination of the relevant agreement.

8. Updates to this Privacy Policy

This Privacy Policy may be revised, changed, updated and/or amended at any time, without notice, at the sole discretion of the Company. When we make changes to this Privacy Policy, we will notify all users on our Website and/or mobile applications, and we will post our revised/updated Privacy Policy.

9. Data Protection Officer.

To exercise all relevant rights, inquiries or complaints about any data protection issue between you and us, please contact our Data Protection Officer in the first instance at: support@nbcgate.com

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