Welcome to the Privacy & Cookie Policy (“Policy”) of the Tokenise Brokerage Limited (“Tokenise Brokerage” “we” “us”)

Tokenise Brokerage respects your privacy and is committed to protecting your personal data. This Policy will inform you as to how we look after your personal data when you visit our website and outlines your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this Policy

This Policy aims to provide you with information on how Tokenise Brokerage collects and processes your personal data through your use of this website, including any data you may provide when you register on this site and/or purchase a product or service offered by Tokenise Brokerage.

This website is not intended for persons under the age of 18 years, and we do not knowingly collect data relating to persons under the age of 18 years.

It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This Policy will supplement other notices and privacy & cookie policies that may be issued from time to time and is not intended to override them.

Controller

A data protection officer (“DPO”) has been appointed and is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Changes to the Policy and your duty to inform us of any changes

When we change the contents/conditions of our existing privacy statements and/or notices, we will take necessary measures to ensure that any changes are communicated to you in such a way that will ensure that you will actually notice them and read them. This means, for example, that a notification of changes will be communicated by way of an appropriate means (e.g., email/ hard copy letter, etc.) specifically devoted to those changes.

It is important that the personal data we hold about you is current and accurate. Please keep us informed if your personal data changes during your relationship with us.

Third-party Link

This website may include links to third-party websites to include companies within the Tokenise Group, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your personal data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include personal data where the identity of the individual has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity data: includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

• Contact Data: includes billing address, delivery address, email address and telephone numbers.

• Financial data: includes bank account and payment card details.

• Transaction Data: includes details about payments to and from you and other details of products and services you have purchased from or through us.

• Technical data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location data, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

• Profile data: includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.

• Usage Data: includes information about how you use our website, products, and services.

• Marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

• We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law, as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data, so that it can directly or indirectly identify you, identify you, this is classed as personal data.

• We do not collect special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that 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 goods or services). In this case, we may not proceed with and or cancel product or service you require from us, but we will notify you if this is the case at the time.

3. How is your personal data collected?

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

Direct interactions. You may give us information about your identity, contact details and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;

• create an account on our website;

• subscribe to our services or publications;

• request marketing materials to be sent to you;

• enter a competition, promotion, or survey; or

• give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see the section ‘Use of our Cookies’ below for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below and technical data from the following parties:

• analytics providers based inside or outside of Barbados;

• advertising networks based inside or outside of Barbados and

• search information providers based inside or outside Barbados.

Also:

• contact, financial and transaction data from providers of technical, payment and delivery services based inside or outside Barbados.

• identity and contact data from marketing lists, tele marketing data or aggregators based inside or outside Barbados.

• identity and contact data from publicly available sources such as from governments sources/records Know Your Client /Anti Money Laundering (“KYC/AML”) service providers based inside and outside Barbados.

4. How we use your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Were we need to perform the contract; we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal obligation.

• We will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal 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: we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Change of purpose

We will only use your personal data for the purpose(s) for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your identity information, contact details, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party Marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting Out

You can ask us or third parties to stop sending you marketing messages by contacting us at any time. You may unsubscribe here: unsubscribe@tokenise.io at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or any other transactions.

Cookies

A Cookie is a small text file that is placed and stored on your computer, mobile or other devices by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information about visitor behaviours to the website owner. The Cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited.

Before Cookies are placed on your computer or device, you will be shown a pop-up prompt requesting your consent to set those Cookies. By giving your consent here you are enabling us to provide the best possible experience and service to you.

Certain features on our website depend on Cookies to function. These Cookies are shown in the table below, your consent will not be sought to place these Cookies, but it is important that you are still aware of them. You may still block these Cookies by changing your internet browser’s settings. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or may not function properly.

You can also choose to delete Cookies on your computer or device at any time. Here is a list of the Cookies we use:

5. Disclosure of your Personal Data

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

1. Internal Third Parties - Other companies which form part of the Tokenise Group and /or third party providers who are acting as joint controllers or processors and who are based globally and provide IT and system administration services and undertake management reporting.

2. External Third Parties:

   • Service providers based inside and outside Barbados who provides KYC/AML services. To Tokenise Brokerage.

   • Service providers based inside and outside the Barbados who provide IT and system administration services.

   • Professional advisers including lawyers, bankers, auditors, and insurers based inside and outside Barbados who provide consultancy, banking, legal, insurance and accounting services.

   • Revenue & Customs, Regulators and other authorities based inside and outside Barbados.

In the event Tokenise Brokerage, choose to sell, transfer or merge parts of our business or our assets, additionally we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law and international best practice. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

We may share your personal data with other members of the Tokenise Group. Tokenise Group. This may involve transferring your data and your data being processed by staff operating inside and outside Barbados. We ensure your personal data is protected by requiring all companies within the Tokenise Group to follow the same rules when processing your personal data.

Personal data will not be transferred to countries outside of Barbados unless there is an adequate level of protection, and they have appropriate safeguards.

Many of our external third party providers are based outside Barbados; therefore the processing of your personal data will involve a transfer of data outside Barbados. Whenever we transfer your personal data out of Barbados, a similar degree of protection is afforded to it as we will only transfer your personal data to third party providers that are based in countries that have been deemed to provide an adequate level of data protection and appropriate safeguards.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach. We will notify you and the applicable regulator or authority of the breach where we are legally required to do so.

8. How and where we store your data

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, 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 personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

Personal data that we collect will not be transferred unless the territory provides an adequate level of protection. The data that we collect from you may be transferred to, and stored at, a destination inside or outside Barbados. It may also be processed by staff operating inside or outside Barbados who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services. Access to your information is limited to those who have a need to manage it.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access

Data subjects may submit a request - to obtain a copy of the personal data that we hold about them in a structured and portable manner.

To make a request please write to the Data Protection Officer at:

Tokenise Brokerage Limited, Burnham Court, Bishop's Court Hill, Upper Collymore Rock, St. Michael, Barbados. or you can email us on: clientservices@tokenise.io

You will need to provide the following documentation for verification purposes:

• Your full name, address, and any reference number we hold for you,

• Identification documents showing name, address, and signature;

• A copy of your driving license or

• A copy of your passport and a recent utility bill or bank statement.

Request correction

We will seek to ensure that inaccurate or incomplete personal data will be rectified. You can request the rectification of your personal data if it is inaccurate or incomplete by contacting us using the details above.

Request erasure (Right to be forgotten)

You can notify us if you wish to exercise your right to erasure. Such a withdrawal of consent does not affect the lawfulness of processing based on statutory purposes which do not require your consent. data subjects that exercise this right will be removed from any marketing or future contact. We may retain a copy of any personal data if the processing is necessary for the establishment, exercise, or defence of legal claims.

Object to processing

You can object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it adversely impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal information which may override your rights and freedoms.

Request restriction

This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the personal data’s accuracy.

• Where our use of the personal data is unlawful, but you do not want us to erase it.

• Where you need us to hold the data even if we no longer require it, as you need it to establish, exercise or defend legal claims.

• You have objected to our use of your personal data, but we need to verify whether we have any overriding legitimate grounds to use it.

Request transfer

You can request a transfer of your personal data to you or to a third party. We will provide to you, or your chosen third party, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information for which you have initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent

Where we are relying on consent to process your personal data, you have the right to withdraw this consent. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Make a complaint

If you have any cause for complaint about our use of your personal data, please contact us using complaint@tokenise.io, we will do our best to solve the problem for you.

10. How to Contact Us

If you have any questions about this Policy or our privacy practices, please contact our Data Protection Officer in the following ways:

Email Us on: dataprotection@tokenise.io

Write to us:

Data Protection Officer

Tokenise Brokerage Limited, Burnham Court, Bishop's Court Hill, Upper Collymore Rock, St. Michael, Barbados

(Updated 7th December 2022)