In Accordance with the General Protection Data Protection Regulations (GDPR) (EU) 2016/679, Roche Fintech T/A New2Markets (N2M) and its employees (N2M) will maintain the privacy of personal information concerning the Company’s current as well as former clients (each a “Client” and collectively “Clients”). These precautions include the adoption of certain procedures designed to maintain and secure such Clients’ nonpublic personal information from inappropriate disclosure to third parties. Federal regulations require N2M to inform Clients of this privacy policy. Except as described in this privacy policy, N2M shall not use Clients’ personal information for any other purpose, unless how such information will be used is explained at the time Clients disclose it to N2M or N2M obtain your permission.

WHAT INFORMATION WE COLLECT FROM YOU

Upon opening an account with New2Markets, information is collected that adhere to our AML / KYC policies. This may include Addresses, Phone Numbers, DOB, Financial Information, Occupation, Business, Government Identification cards/Issued ID numbers/Passports and, other publically /non publicly held information. This information is used to verify identity of New2Markets Clients, Introducing Brokers. Information is also use to ensure proper funding and withdrawals information. Information may be obtained in electronic, or handwritten format.

HOW LONG WILL DATA BE KEPT AND HOW LONG WILL IT BE STORED

New2Markets will retain all identification records for 5 years after the account is closed. Data is deleted after this time.

N2M shall protect the confidentiality of Clients’ written and electronic records and other sensitive information.

N2M employees shall take reasonable steps to ensure that Clients’ records are stored in a secure location and that Clients’ records are not available to others who are not authorized to have access.

N2M shall take precautions to ensure and maintain the confidentiality of information transmitted to other parties through the use of computers, electronic mail, facsimile machines, telephones and telephone answering machines, and other electronic or computer technology. Disclosure of identifying information should be avoided whenever possible.

WITH WHOM WE SHARE YOUR INFORMATION

N2M shall not disclose any nonpublic personal information about its prospective, existing or former Customers to anyone, except as permitted by law and regulation or under certain limited circumstances more fully described below.

N2M shall restrict access to nonpublic personal information regarding its Clients to those employees and agents of N2M who need to know that information in order to provide services to its Customers.

N2M may also disclose such information to its affiliates and to service providers and financial institutions that provide services to N2M.

In such cases, N2M shall require such third party service providers and financial institutions to protect the confidentiality of the Customers’ nonpublic personal information and to use the information only for purposes for which it is disclosed to them.

N2M maintains physical, electronic, and procedural safeguards that comply with federal standards to safeguard the Customers’ nonpublic personal information and which RF believes are adequate to prevent unauthorized disclosure of such information.

N2M may disclose confidential information only when the appropriate with valid consent from a Client or a person legally authorized to consent on behalf of a Client or as required by applicable laws and regulations.

Upon Request, N2M shall discuss with a Client and other interested parties the nature of confidentiality and limitations of Client’s right to confidentiality.

N2M shall review with Clients, circumstances where confidential information may be requested and where disclosure of confidential information may be legally required. This discussion should occur as soon as possible in the employee-client relationship and as needed throughout the course of the relationship.

N2M shall not disclose confidential information to third-party payers unless Clients have authorized such disclosure.

N2M shall not discuss confidential information in any setting unless privacy can be reasonably ensured. N2M shall not discuss confidential information in public or semipublic areas including, but not limited to, hallways, waiting rooms, elevators, and restaurants.

N2M shall not disclose identifying information when discussing Clients for teaching or training purposes unless Client has consented to disclosure of confidential information.

Clients are not required to supply any of the personal information that N2M may request; however, failure to do so may result in N2M being unable to provide services request by such Clients. While N2M make every effort to ensure that all information N2M hold about Clients are current, accurate, and complete, Clients can help N2M by prompt notice to N2M if there are any changes to Client’s personal information.