TDMFX

TDMFX respects your privacy and is committed to protecting and respecting your

personal data. This privacy policy aims to give you information on how we collect

and process any personal data, i.e. information about a Client (as defined below)

who is a natural person on the basis of which that Client can be identified

(hereinafter the data) in accordance with the applicable data protection legislation

and best practice.

We strive to create the most secure infrastructure of any broker in the world. In this

assured that your data is safe.

It is important that you read this privacy policy together with any other privacy policy

we may provide on specific occasions when we are collecting or processing your

data about you so that you are fully aware of how and why we are using your data.

In this Privacy Policy, unless the context otherwise requires, expressions defined

herein shall have the meaning ascribed to them in the Terms & Conditions.

Please note that this Privacy Policy is addressed to current and prospective Clients.

If you are an employee, contractor or a third-party service provider, your personal

information will be used in connection with your employment contract, your

contractual relationship or in accordance with our separate policies which are

available by contacting us at the contact details listed in the section OUR CONTACT

DETAILS below.

If you are participating in our affiliate program and/or introducing broker program, we

will process the data provided under our agreement with you to exercise our rights

and perform our obligations under or in connection with the relevant agreement and

the term Client in this Privacy Policy shall be read to include the term Affiliate and/or

Introducing Broker (as applicable).

1. WHO WE ARE

TDMFX, is a global brand, which is operated by TMP Software Inc, and/or its

affiliated and/or related entities (hereinafter “We” or “Company” or “TDMFX”). We

are the controller and responsible for the data of the Client disclosed to us in order to

services offered by us through the website (hereinafter “Website”) (this term shall at

all times include Website’s desktop and mobile versions).

This Privacy Policy is issued on behalf of TMP Software Inc. the company

responsible for collecting and/or processing your data when you use the Trading

Platform through the Website, either for a Trading Account or a Demo Account (or

their mobile/desktop versions) (hereinafter the Service(s)). We respect your privacy,

and we are committed to protecting your data, which we collect, use and/or have

access to.

We take measures to implement advanced data protection policies and procedures

and to update them from time to time for the purpose of safeguarding the Client's

data and the Client’s account. Your data is protected by the legal, administrative and

technical measures that we take to ensure the privacy, integrity and accessibility of

data. To prevent security incidents with your data, we use a mixed organizational and

technical approach based on the results of annual risk assessment.

We shall not divulge any private information of our Clients and former Clients unless

the Client approves in writing such disclosure or unless such disclosure is required

under applicable law or is required in order to verify the Client's identity, or it is

required for us to perform our contractual obligations under any agreement

concluded with the Client. The Clients' information is processed only by our

employees and/or trusted third parties which provide specific services necessary for

the provision of our services. All such information shall be stored on electronic and

physical storage media according to applicable law.

2. DATA USAGE

1. We may collect, use, store and transfer different kinds of data about you which we

have grouped together as follows:

● Identity Data includes first name, last name, and patronymic (if available),

date of birth, gender, passport, ID, Driver’s number, and copy of photo.

● Contact Data includes billing address, email address and telephone numbers.

● Financial Data includes bank account, payment card details and tax

identification numbers (including but not limited to social security number,

income tax identification number, national insurance number).

● Transaction Data includes details about the transactions performed by you,

details about payments, withdrawals, exchanges, trading history, profit,

balance, deposit and withdrawal amount and methods, and any other details

in relation to the services you have made use of through our Website.

● Technical Data includes internet protocol (IP) address, your login data,

browser type and version, time zone setting and location, browser plug-in type

and versions, operating system and platform, and other technologies on the

devices you use to access the Website and use of cookies stored on your

device.

● Profile Data includes your Client Account details, username and password,

transactions made by you, your interests, preferences, feedback and/or

information received through your interaction with us within the course of

providing our services and survey responses.

● Usage Data includes information about how you use the Website, products

and services, registration date, account category, trading cluster, number of

complaints, number of requests filed and IP history.

● Marketing and Communication Data includes your preferences in receiving

marketing from us and your communication preferences.

● Special Categories of Data/ ‘Sensitive’ Data includes details about your

religious belief, annual income, biometric data and/or criminal convictions and

offenses.

● Conformity Data includes details about your education, employment status,

trading experience, self-assessment test.

● Banking Data includes details of the number of payment wallets and/or

information of your bank card, including information of the issuing bank, card

number, cardholder name, card expiration date, payment system, card

validation code (CVV2 / CVC2), and photos of both sides of the bank card.

● Data in KYC (Know your customer) includes identity document information,

including copies of recently dated Utility Bills, Identity Card, Passport, and/or

Driver’s License.

● Economic Profile Data includes details on occupation, purpose of investment,

annual income, net wealth, expected annual amount of investment and

sources of funds.

● Location Data includes details on your actual location when interacting with

our Website (for example, a set of parameters that determine regional settings

of your interface, namely residency country, time zone, and the interface

language)

● Audio Data includes full voice recordings of calls that you receive from us or

make to us. (the above collectively referred to as Personal Data)

2. Aggregated Data includes statistical or demographic data for any purpose. Such

data can be derived from your data but may not be considered personal data in law

as it will not directly or indirectly reveal your identity. An example of such Aggregated

Data could be that we aggregate your Usage Data to calculate the percentage of

users accessing a specific website feature and/or services/product preference.

Notwithstanding the above, if we combine Aggregate Data with data in a way that the

end result can in any way identify the data subject, we shall treat such combined

data as data which will be treated as per the provisions herein contained.

Processing of your data is carried out by us following the principles of lawfulness,

fairness, transparency, and always adhering to the intended purpose of data

processing, the principle of data minimization, accuracy, limited data storage, data

integrity, confidentiality and accountability.

In general, we collect and process the Personal Data, for any of the following

reasons:

1. To perform our contract with you,

2. To comply with our legal obligations, including without limitation to applicable

anti-money laundering and terrorist financing laws and regulations (hereby

referred to as money-laundering acts), and/or

3. To safeguard our legitimate interests.

The Client acknowledges that all or part of the data concerning the Client's account

and related transactions will be stored by us and may be used by us in case of

dispute between us and the Client.

The Client is responsible for updating any data provided to us in case of any change.

Although we will strive to keep your data up to date and review and inspect any

information provided by you, we may not be able to always do so without your help.

The Client acknowledges that we hold neither commitment nor responsibility to the

Client due to any aforesaid review or inspection of information.

3. HOW IS YOUR PERSONAL DATA COLLECTED

We use different methods to collect data from and about you, including through:

Direct Interactions. You will provide to us your Identity, Contact and Financial Data

online through the Website and/or by filling in online forms and/or by corresponding

with us by emails or otherwise. Data may be submitted to us by you when you wish

to:

1. Register for a Trading Account;

2. Register for a Demo Account;

3. Subscribe to our publications and ongoing updates;

4. Request marketing and promotions to be sent to you;

5. Enter a competition, promotion or survey; and/or

6. Give us feedback or contact us.

We require collecting the above data in order that we are able to (i) provide our

services efficiently, (ii) to comply with our ongoing legal obligations, including, inter

alia, to prevent fraud and money laundering acts.

If you fail to provide the data when requested, we may not be able to perform the

contract we have or are trying to enter into with you (for example, to provide you with

our services). In this case, we may have to cancel a service you have with us, but we

will notify you if this is the case at the time. It is important that the data we hold about

you is accurate and current. Please keep us informed if your data changes during

your relationship with us.

Automated Technologies or Interactions. When using our Services, your device

automatically transmits to us its technical characteristics. Locale (a set of parameters

that determine regional settings of your interface, namely, residence country, time

zone and the interface language) is used for the purpose of providing you with the

best possible service within our platform. Using the information about IP address,

cookies files, information about browser and operating system used, the date and

time of access to the site, and the requested pages addresses allows us to provide

you with the optimal operation on our web application, mobile and/or desktop

versions of our application and monitor your behavior for the purpose of improving

the efficiency and usability of our Services. We use web analytics tools to track the

performance of our website and marketing source of users by cookies in order to

optimize our marketing costs and provide users with a better experience. You may at

any time request that we refrain from any such transmissions (to the degree this is

possible and subject to any of our legal obligations) by sending your request to the

DPO using our details in the OUR CONTACT DETAILS below using the registered

email address you disclosed and registered with us through your Account. We will

address your request within 30 business days.

About Cookies:

A cookie is a small amount of data that often includes a unique identifier that is sent

to your computer or device browser from a website's computer and is stored on your

device's hard drive for tracking site usage. A website may send its own cookie to

your browser if your browser's preferences allow it, but, to protect your privacy, your

browser only permits a website to access the cookies it has already sent to you, not

the cookies sent to you by other websites. Many websites do this whenever a user

visits their website in order to track online traffic flows. When you visit our Website,

our system automatically collects information about your visit, such as your Technical

Data, including inter alia to, your browser type, your IP address and the referring

website.

Cookies stored may determine the path the Client took on our site and used to

anonymously identify repeat users of the website and what pages were most popular

for Clients. However, we protect the Client’s privacy by not storing the Client’s

names, personal details, emails, etc. Using cookies is an industry standard and is

currently used by most major websites. Stored cookies allow the Website to be more

user-friendly and efficient for Clients by allowing Goshawk to learn what information

is more valued by Clients versus what isn’t. You can set your browser not to save

any cookies from this website, and you may also delete cookies automatically or

manually. However, please note that by doing so, you may not be able to use all the

provided functions of our website in full.

Please see our Cookies Policy for further details.

4. PURPOSE FOR WHICH WE WILL USE YOUR DATA AND ON WHAT LEGAL

BASIS

1. We process the aforementioned data in compliance with the applicable legislation as

amended from time to time in order to (i) be able to perform our contractual

obligations towards the Client and offer them the best possible service, (ii) provide

our Services efficiently, (iii) comply with our legal obligations, including, inter alia, to

prevent fraud and money laundering acts, and (iv) protect our legitimate interests

and your vital interests.

2. We process all data based on the following legal basis:

1. For compliance with our legal obligations;

2. For the performance of our contractual obligations towards the Client;

3. For the purposes of safeguarding our legitimate interests and your interests

and fundamental rights do not override those interests; and/or

4. On the basis of your consent.

3. Indicatively we set out below, a description of all the ways we plan to use your data

and which of the legal bases we rely on to do so. We have also identified what our

legitimate interests are where appropriate. Note that we may process the data for

more than one lawful ground, depending on the specific purpose for which we are

using your data.

PURPOSE ACTIVITY

TYPE OF DATA

LAWFUL BASIS FOR

PROCESSING, INCLUDING

BASIS OF LEGITIMATE

INTEREST

1. To accept to register you as a

Client

2. To notify you about changes to

our terms or privacy policy

3. To communicate with you and

provide you with secure

identification, authentication and

support services

4. To confirm you are at the age

of majority as recognized and

declared by the laws of your

jurisdiction

1. Identity Data

2. Profile Data

3. Contact Data

4. Data in KYC

5. Financial

Data

6. Economic

Profile Data

1. Necessary to perform our

contract with you

2. Necessary to comply with our

legal obligations

1. To perform our Scoring

Processing under which a Client

is scored on a scale basis with

regard to the level of risk he is to

Goshawk

1. Banking Data

2. Economic

Profile Data

1. Necessary to perform our

contract with you

2. Necessary to comply with our

legal obligations

1. To confirm the information

provided by You under (a) above

in relation to your location.

1. Location Data

1. Necessary to perform our

contract with you

2. Necessary to comply with our

legal obligations

1. To secure authentication,

identification and support services

via social networks protocols and

use the links to your accounts in

social networks for these

purposes.

1. Technical

Data

1. Necessary to perform our

contract with you

2. Necessary to comply with our

legal obligations

1. To process and deliver your

transactions and requests

(Deposits; Trades; Withdrawals)

2. Manage payments, fees and

charges;

3. To collect and recover money

owed to us.

1. Banking Data

2. Transaction

Data

1. Necessary to perform our

contract with you

2. Necessary for our legitimate

interest (recover charges owed to

us, make a withdrawal in case of

breach of our contract)

1. To administer and protect our

business and Website (including

troubleshooting, data analysis,

testing, system maintenance,

1. Identity Data

2. Contact Data

3. Technical

Data

1. Performance of our contract with

you

2. Necessary to comply with our

legal obligations

3. Necessary for our legitimate

support, reporting and hosting of

data)

interests (take reasonable steps to

confirm that you do not use any

ways to manipulate our platform &

for running our business, provision

of administration and IT services,

network security, to prevent fraud)

1. To deliver relevant Website

content and advertisements to

you and measure or understand

the effectiveness of the

advertising we serve to you

2. To provide you with an optimal

operation on our web application,

mobile and/or desktop versions of

our application and monitor your

behavior for the purpose of

improving the efficiency and

usability of our services.

1. Identity Data

2. Contact Data

3. Profile Data

4. Usage Data

Technical Data

5. Marketing and

Communication

Data

1. Necessary to perform our

contract with you

2. Necessary for our legitimate

interests (to study how customers

use our products/services, to

develop them, to grow our

business)

1. to study how customers use

our products/services, to develop

them, to grow our business and to

inform our marketing strategy;

2. statutory limitations

1. Transaction

Data

1. Necessary for our legitimate

interests (including statutory

limitations provisions by applicable

laws)

1. To inform you about any of the

following:

— new services and/or products

we may offer;

— Any new development and/or

features of the current

products/services we offer

1. Identity Data

2. Profile Data

3. Contact Data

4. Technical

Data

5. Usage Data

6. Transactions

7. Marketing and

Communication

Data

1. Necessary to perform our

contract with you

2. Necessary for our legitimate

interests (to study how customers

use our products/services, to

develop our products/services and

grow our business)

1. To send direct marketing of our

services to you, always within the

boundaries of our legitimate

interests.

2. To send to you newsletters,

push-messages and calls to keep

you in touch with our new

features and new development of

the current products/services we

offer, news and events and the

efficient provision of the full scope

of our services.

Please note that we will never use

your data to communicate to you

1. Identity Data

2. Profile Data

3. Contact Data

4. Data that may

be provided by

you during your

activity at the

Website.

Marketing and

Communication

Data

1. Necessary to perform our

contract with you

2. Necessary for our legitimate

interests (to provide effective and

personalized customer services to

you and to update you in relation to

our services that are available to

you.

and/or promote any third-party

marketing material.

1. To allow us to provide you with

the optimal operation on our

Website, mobile and desktop

versions of our application and

monitor your behavior for the

purpose of improving the

efficiency and usability of our

Services.

2. To use analytics tools to track

the performance of the Website

and marketing source of our

Clients in order to optimize our

marketing costs and provide you

with a better experience.

1. Location Data

2. Technical

Data

3. Usage Data

4. Marketing and

Communication

Data

1. Necessary to perform our

contract with you

2. Necessary for our legitimate

interests (to provide effective and

personalized customer services to

you and to update you in relation to

our services that are available to

you).

1. to allow us to monitor and train

our employees for your benefit

2. to safeguard your or our

interests in case of a dispute

3. to take steps for fraud

prevention

4. to improve the services

provided to you

Audio Data

1. Necessary to perform our

contract with you

2. Necessary to comply with our

legal obligations

3. Necessary for our legitimate

interests

1. To confirm that your annual

income corresponds with your

employment status

2. To confirm that you have no

criminal history.

Sensitive Data

1. Necessary to comply with our

legal obligations

2. Necessary to protect your vital

interests.

4. If you are an existing Client of the Website where we have a legitimate interest in

communicating with you, or if you have given us your consent, we will collect and

process your personal data to communicate with you in case of support and/or

sending newsletters, push-messages and calls to keep you in touch with our new

features, news and events and the efficient provision of the full scope of our services.

We will also use your data to send you marketing information regarding our services

that we believe may be of interest to you via email or otherwise.

5. Our Website is not intended for children, and we do not knowingly collect data

relating to children. As we do not allow users under the age of 18 to use our services,

we need to obtain your birthdate in order to confirm the Clients’ age checks.

5. OPTING OUT

If you do not want to receive any marketing newsletters or transmit your data to third

parties for marketing purposes, you can configure your preferences. Such

configuring can be done when (i) opening an account or (ii) when receiving such

advertising content or (iii) by logging in and going to My Account > Personal Details

> Notification Settings. You may also send us, at any time, an email to

support@TDMFX.com using the registered email address you disclosed and

registered with us through your Account asking us to cease from sending such

advertising content or sending your data to third parties for marketing purposes. The

aforesaid mark removal and/or e-mail received by Goshawk will oblige us to cease

sending advertisement content to you within 7 (seven) business days.

6. DISCLOSURE OF DATA

We may share your data with the parties for the purposes set out above.

We take all reasonable steps so that our third-party service providers do not use

your personal data for their own purposes, and only permit them to process your

data for specific purposes and in accordance with our instructions.

In general, your data is used by our processors.

In addition, a transfer of your data to another legal entity may occur as part of a

transfer of our business or parts thereof in the form of a reorganization, sale of

assets, consolidation, merger or similar.

With regard to the transfer of data to recipients outside our related and/or affiliated

entities, we note that we strive to maintain discretion with respect to client related

matters and assessments of which we acquire knowledge. We may disclose data

that concerns you only if (i) we are legally required to do so; (ii) if required when you

expressly order us to process a transaction or any other service and (iii) it is required

for the provision of our services under our contractual relationship and/or (iv)

protection of our legitimate interests and applicable legislation as amended from time

to time.

External Third Parties. Your data is shared with third-party organizations/entities,

including but not limited to:

A. Service Providers. We may share your data with our trusted third-party service

providers, who, on our behalf, operate, maintain, and/or support our IT systems and

IT infrastructure, our websites, manage our payment solutions, perform statistical

analysis, marketing and advertising purposes, sending newsletters, provide

customer support and perform other important services for us.

B. Other related and/or affiliate entities. We may also disclose your data to other

Goshawk Affiliate companies in order for them to provide us with the relevant

services.

C. State authorities. Your details that are provided and/or that will be provided by

you during your activity on the Website may be disclosed by us to official authorities.

We will make such disclosure only if required to be disclosed by us under the

applicable law or court order and to the minimum required extent.

D. Other disclosures. In addition to where you have consented to a disclosure of

the data or where disclosure is necessary to achieve the purpose(s) for which, it was

collected, data may also be disclosed in special situations, where we have reason to

believe that doing so is necessary to identify, contact or bring legal action against

anyone damaging, injuring, or interfering (intentionally or unintentionally) with our

rights or property, users, or anyone else who could be harmed by such activities, or

otherwise where necessary for the establishment, exercise or defense of legal claims.

Where reasonably possible, management shall ensure that third parties collecting,

storing or processing personal information, on our behalf, have:

a. Signed agreements to protect personal information consistent with this Privacy

Policy and information security practices or implemented measures as prescribed by

applicable laws;

b. Signed non-disclosure agreements or confidentiality agreements which include

privacy clauses in the contract; and

c. Established procedures to meet the terms of their agreement with third parties to

protect personal information.

Remedial action shall be taken in response to misuse or unauthorized disclosure of

personal information by a third-party collecting, storing or processing personal

information on behalf of Goshawk.

If you want to obtain further information on any data transfers mentioned above,

please contact us using the registered email address you disclosed and registered

with us through your Account through the points of contact listed in the Section OUR

CONTACT DETAILS below.

7. DATA RETENTION

We store your data for as long as reasonably necessary to fulfill the purposes we

collected it for, including for the purposes of satisfying any legal, tax, accounting or

reporting requirements. We may retain your personal data for a longer period in the

event of a complaint or if we reasonably believe there is a prospect of litigation in

respect to our relationship with you.

To determine the appropriate retention period for your data, we consider the amount,

nature and sensitivity of the data, the potential risk of harm from unauthorized use or

disclosure of your data, the purposes for which we process your data and whether

we can achieve those purposes through other means, and the applicable legal, tax,

accounting and other requirements.

We shall keep your data (including call recordings) during our contractual

relationship and for a minimum period of 7 (seven) years from the date of termination

of the Service used by you.

In general, all other data is stored for a period of 30 (thirty) business days after the

date of termination of the provision of our Services, unless there is any other legal

reason to keep it.

At the expiration of the data retention period the data is erased by irreversible

destruction, and we also inform all third parties, to whom the data was transferred,

regarding such erasure and request implementation of similar actions on their part.

8. YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE

We ask you to provide us with true, accurate and updated information on your

identity and not misrepresent yourself to be another individual or legal entity. Any

changes in your identifying details shall be notified to us immediately and in any case

no later than the 7th day from the date of such changes. If your data is incorrect or

incomplete, please contact us at the contact details listed in the section OUR

CONTACT DETAILS below in order to change your data.

Under certain circumstances, you have rights in accordance with applicable

legislation and our policies as amended from time to time. Some of the rights are

rather complex and include exemptions; thus, we strongly advise you to contact us

(at the contact details listed in the section OUR CONTACT DETAILS below). You can

find a summary of your rights below in this section.

A. The right to access. You have a right to obtain the confirmation as to whether or

not your data is being processed by us. In addition, you have a right to obtain more

detailed information about the data kept and the processing undertaken by us and

under certain circumstances the right to receive a copy of this data. In order to

access and view your data without downloading it, please go to the 'Access my data'

in your personal cabinet, by logging onto your Account, going to Personal Data and

at the bottom of the page you can proceed with your request by selecting A ccess

my Data. In addition, you have a right to obtain more detailed information about the

data kept and the processing undertaken by us and under certain circumstances the

right to receive a copy of this data.

B. The right to rectification. You have the right to have inaccurate data about you

rectified, and, taking into account the purpose of the processing, to have incomplete

data completed.

C. The right to erasure. This enables you to ask us to delete or remove personal

data where there is no good reason for us continuing to process it. In order to Delete

your Account and all the personal data currently stored in our system, you can do so,

by logging into your Account, going to the P ersonal Data section and then Account

Settings and at the bottom of the page, you can proceed with your request by

selecting – Terminate Account – Delete My Account and all of its data. Please note

however that we may not always be able to comply with your request for erasure for

specific legal reasons which will be notified to you, if applicable, at the time of your

request. In case if you want to obtain complete erasure of your data (to apply the

“right to be forgotten”), please note that we may not always be able to comply with

your request of erasure for specific legal reasons which will be notified to you, if

applicable, at the time of your request.

D. The right to restriction of processing. You have the right to request the

restriction of processing of your personal data (a) if it is not accurate;(b) where

processing may be unlawful, but you do not want us to erase your data; (c) where

you need us to hold the data even if we no longer require it; or (d) where you may

have objected to our use of your data, but we need to verify whether we have

overriding legitimate grounds to use it.

E. The right to data portability. To the extent the legal basis for the processing is

your consent, and such processing is carried out by automated means, you have the

right to receive your data in a structured, commonly used and machine-readable

format. However, this right does not apply where it would adversely affect the rights

and freedoms of others and/or in case it may be technically impossible to do so.

F. The right to object. Subject to the legal basis on which the processing activity is

based, you may object to processing of your personal data. Please note that in some

cases, we may have compelling legitimate grounds to process your information

which we need to comply with.

G. The right to withdraw consent. To the extent that the legal basis for the

processing is your consent, you have the right to withdraw from that consent at any

time. This may apply to marketing purposes and/or with regard to the transfer of your

data to third parties. In case you withdraw from a consent given, then we will cease

to process your data, unless and to the extent the continued processing is permitted

or required according to the applicable data regulation or other applicable laws and

regulations. The withdrawal of your consent will in no event affect the lawfulness of

processing based on consent before its withdrawal.

H. The right to complain to the data protection supervisory authority. We do our

best to ensure that we protect your data, keep you informed about how we process

your data, and comply with the applicable data protection regulations. In case you

are not satisfied with the processing and protection of your data or the information

you have received from us, then we urge you to inform us in order for us to improve.

Please also do not hesitate to contact us, if you want to make use of your rights.

If you want to exercise any of your rights mentioned above and/or obtain more

information regarding your rights and/or our policies and procedures, please contact

us through the points of contact listed in the Section OUR CONTACT DETAILS below.

Please also provide us with relevant information to take care of your request,

including your full name and email address so that we can identify you. We will

respond to your request without undue delay.

We may need to request specific information from you to help us confirm your

identity and ensure your right to access your data (or to exercise any of your other

rights). This is a security measure to ensure that personal data is not disclosed to

any person who has no right to receive it. We may also contact you to ask you for

further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally, it could

take longer than a month if your request is particularly complex, or you have made a

number of requests. In this case, we will notify you and keep you updated.

We may charge you a reasonable administrative fee for any unreasonable or

excessive requests we may receive, and for any additional copies of the data you

may request.

9. DATA SECURITY

We have put in place appropriate security measures to prevent your data from being

accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In

addition, we limit access to your data to those employees, agents, contractors and

other third parties who have a business need to know. They will only process your

data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data breach and will

notify you of a breach where we are legally required to do so.

Your help is always valuable in ensuring that your data is kept safe. Upon registration

to the Website (or its mobile version), the Client will be asked to choose a username

and password to be used by the Client on each future login and for the performance

of transactions and use of the Services. In order to protect the Client's privacy and

operation with the Website, sharing registration details (including, without limitation,

username and password) by the Client with other persons or business entities is

strictly prohibited. We shall not be held responsible for any damage or loss caused to

the Client due to improper use (including prohibited and unprotected use) or storage

of such username and password, including any such use made by a third party, and

whether or not known to or authorized by the Client.

The Company’s live public chat feature is not an official channel of communication

between the Company and you. We will never communicate with you via the live

public chat feature, and we will never ask for any information, including any personal

data, via the live public chat feature. The live public chat feature is designed for

public conversations and as a tool to allow users to communicate and interact

between them in real time around the topic(s) they are interested in. Please note that

the live public chat features non-private channels of communication, information

communicated via the live public chat feature can be accessed by any person. We

do not control the content shared via the live public chat feature, and we shall not be

held responsible in any way and for any actions taken or information shared via the

live public chat feature..

Any use of the Website with the Client's username and password is the Client's sole

responsibility. We shall not be held responsible for any such use, including for

validation that the Client is actually operating in his/her account.

You are obliged to forthwith notify us of any suspicion of unauthorized use of the

Client Account. You may contact us at any time through the points of contact listed in

the Section OUR CONTACT DETAILS below.

Encryption of your data in transit. Encryption provides a high level of security and

privacy for your data. When you enter your data on our platform, we use strong

encryption technologies (such as Transport Layer Security) to protect your data

during transmission from your devices to our servers.

For providing more trust and security, we use digital EV (Extended Validation)

Certificates issued by trusted Certificate Authorities. You can see the ‘Green Bar’ in

the supported browser versions which confirms what all transmitted data is secure.

Protection of your data in our infrastructure. We make it a priority to develop

services that are secure “by default”. The “default” security of our services means

that all new services and features are designed with strict security requirements in

mind before we even begin development. This is the key to guaranteed protection

and privacy of all data that our services handle and store, once the service or new

feature is released.

To secure your data, we use the pseudonymization which allows most of our services

to operate without using your actual data. Instead of that, our services use a system

ID that can't be traced back to identify you.

We are always vigilant about the security of your data stored in our infrastructure.

Because of that, we locate all our equipment which is used for your data processing

in secure data centers. Network access to this equipment is isolated from the

Internet. We use network segmentation for isolation of services which need different

levels of security from each other. In addition, we restrict logical access to your data

for our employees on a “need to know” basis. So, only the personnel that really

require access to your data for the purpose of providing you with our best service,

will have access to it.

Threats protection. We are highly knowledgeable about modern threats to data

security and privacy, and we are well-prepared to combat them. All events that occur

in our infrastructure are continuously monitored, analyzed and responded to, which

allows us to ensure proper protection of your data, keeping it safe from threats,

vulnerabilities, and the effects of malware.

In the event of a failure that affects the accessibility of your data, we have data

backup and recovery procedures in place that will help us restore your data in a

short time. To guarantee quick recovery, we use high availability mode enabled for

most critical databases, which allows us to minimize downtime.

Employee awareness of data security. Our employees may handle your data in

order to provide you with first-class service. To guarantee the security and

confidentiality of your data, we monitor all employees’ actions with access to your

data in our systems and grant access strictly on a “need to know” basis: only

employees who need access will receive it. We hold regular training sessions to

make sure that each employee understands the principles that we follow to achieve

robust data security and privacy.

If you choose not to give your personal information. In the context of our

business relationship, we may need to collect data by law, or under the terms of a

contract we have with you. Without this data, we are, in principle, not in a position to

close or execute a contract with you.

If you choose not to give us this data, it may delay or prevent us from meeting our

obligations. It may also mean that we cannot perform services needed to run your

accounts or policies.

To what extent we carry automated decision-making and profiling. In

establishing and carrying out a business relationship, we generally do not use

automated decision-making. If we use this procedure in individual cases, we will

inform you of this separately. In some cases, we may proceed with profiling in order

to evaluate certain personal aspects. We shall inform you accordingly in case we

perform any profiling. In general, any data collection that is optional would be made

clear at the point of collection.

10. OUR CONTACT DETAILS

We have appointed a data protection officer (hereinafter DPO) who is responsible

for overseeing questions in relation to this Privacy Policy. If you have any questions

about this privacy policy, including requests relating to the data, please contact the

DPO using the details set out below:

Address:

Friendship Building, Papanga, Philippines

Email:

supporto@TDMFX.com

To enable us to process your request, please contact us using the registered email

address you disclosed and registered with us through your Client Account. We may

require that you provide us with proof of your identity, such as by providing us with a

copy of a valid form of identification. This is to ensure that we appropriately protect

the personal data we hold from unauthorized access requests and comply with our

security obligations.

If you have any questions, or want more details about how we use your data, you

may contact us at the above contact details, and we will be happy to provide you

with further details.

11. LINKS TO OTHER WEBSITES

We may provide links to third-party websites on our Website. These linked websites

are not under our control, and we therefore cannot accept responsibility or liability for

the conduct of third parties linked to our websites, including without limitation to the

collection or disclosure of your data. Before disclosing your data on any other

website, we encourage you to examine the terms and conditions of using that

website and its privacy policies.

12. CHANGES TO THIS PRIVACY POLICY

1. This Privacy Policy was last updated on July 11, 2023. We reserve the right, at

our discretion, to add, modify or remove portions of this Privacy Policy in the

future to ensure that the information herein provides relevant and adequate

information about our collecting and processing of your data.

2. This privacy policy may be supplemented by other information received from us

and other terms and conditions applicable to the Website or which you have

agreed to as part of your interaction with us.

3. In case of updates, we will post the revised Privacy Policy on our website.

Changes will take effect as soon as the revised version is made available on our

website. Your comments and feedback are always welcome. You may contact us

at any time through the points of contact listed in the Section OUR CONTACT

DETAILS above.