Introduction

1.22 r limit applicable to you or in respect of your dealings with us.

2. Closing a Transaction

Transactions with no Expiry Date

2.22 Subject to any other provision in this Agreement and any requirement we may specify in relation to

Linked Transactions, you may Close Out an Open Position or any part of such Open Position at any

time.

2.23 When you Close Out an Open Position, the Closing Level will be, if you are Closing Out an Undated

Buy Transaction, the lower figure then quoted by us and, if you are Closing Out an Undated Sell

Transaction, the higher figure then quoted by us.

2.24 At any time, you may give IC Markets Global notice of your intention to Close Out any Transaction

(whether in whole or part) by specifying the Underlying Instrument and the quantity that you wish

to close. This must be done by you placing an Order which, if accepted, would Close Out the Undated

Transaction that you wish to

close.

2.25 Upon receipt of notice of

intent to Close Out an Undated Transaction (by way of receiving your Order), IC Markets G

IC Markets Global is the trading name of Raw Trading Ltd regulated by the Financial Services Authority of Seychelles

with License Number SD018 and the Head Office at Eden Plaza, Office 222, Eden Island, Mahe, Seychelles.

JANUARY 2023

IC Markets Global – Privacy Policy January 2023 V:1.5 | 2

This Policy is in line with Article 24 GDPR (EU) 2016/679, taking into account the nature, scope, context and

purposes of processing as well as the risks to the rights and freedoms of natural persons, IC Markets Global

has implemented appropriate technical and organisational measures to ensure pursuance to the General

Data Protection Regulation (GDPR). This policy stands the cornerstone to IC Markets Global compliance

with GDPR and is reviewed and updated accordingly.

This Policy that provides data subjects with information on how IC Markets Global collects personal data,

what they do with it and with whom it may be shared. This privacy notice has been drafted in compliance

with the requirements of the General Protection Regulation, Regulation (EU) 2016/679, (the “GDPR”) and

on the basis of the information Commissioner’s Code of Practice on “Privacy notices, transparency and

control” and the Article 29 European Commission Guidelines on transparency under the GDPR.

We ask that you read this privacy notice carefully as we would like to inform you that your privacy on the

internet is of crucial importance to us and it also contains important information on who we are, how and

why we collect, store, use and share personal information, your rights in relation to your personal

information and on how to contact us and supervisory authorities in the event you have a complaint.

1. Who we are?

IC Markets Global (“us”, “our” or “we”) collects, uses and is responsible for certain personal information

about you. When we do so we are regulated under the General Data Protection Regulation which applies

across the European Union and we are responsible as “controller” of that personal information for the

purposes of those laws.

2. Data Controllers and Contracting Parties

Regardless of whether you reside inside or outside the “Designated Countries”, IC Markets Global will be the

controller of your personal data provided to, or collected by or for, or processed in connection with our

services and regulated activities.

3. Whether information has to be provided by you, and if so why

The provision of “Your Data” is required from you to enable us to provide our services. We will inform you

at the point of collecting information from you, whether you are required to provide the information to us.

4. Information collected by us

In the course of your registration as a client, signing up for a demo or a live account with IC Markets Global

or filling in any form on our Website, subscribing to our services, news or offers, marketing communications

or posting material, the following information about you (“Your Data”) will be collected and stored for

administrative, service related and/or legal purposes.

IC Markets Global – Privacy Policy January 2023 V:1.5 | 3

We will limit the collection of personal information to what is necessary to administer our business and carry

out our regulated activities in an effort to provide you with superior service,

Information that you provide to us directly:

• Personal information, such as names, addresses, personal registration number, national identification

number, passport number and email addresses etc (“Personal Information”), and

• Financial Information, trading experience and employment information for appropriateness assessment

will also be collected.

However, the meaning of data “provided to” IC Markets Global is not limited to this. It is also personal data

resulting from observation of your activities (i.e where using a device or service).

This may include:

• History of website usage or search activities, details of your visits to our Website including,

communication data;

• Traffic and location data;

• Website traffic pattern information, including IP address, operating system and browser type, for system

administration and to report aggregate information to our advertisers. This kind of information is only

used in masked or aggregated form, which means that the individual user will not be recognisable. These

data do not identify any individual.

• Communications between you and IC Markets Global via Live Chat, email, or telephone call.

Your e-mail address may be used by IC Markets Global in relation to its products and services (including any

marketing campaigns related to these products or services). If you do not wish to receive such marketing

material and marketing communications, you can opt-out at any time by clicking on “unsubscribe” or by

sending an email stating so to enquiries@icmarkets.com

5. The type of data collected and purpose of collection

The type of data we collect along with the purpose for collection is listed below:

Personal data type: Purpose:

Personal information such as

gender, name, date of birth and

address

To meet our anti money laundering (AML) and other

regulatory AML) and other regulatory obligations in

relation to Know Your Client (KYC) and client due

diligence. To verify your identity using our verification

processes.

IC Markets Global – Privacy Policy January 2023 V:1.5 | 4

Contact information (email address

and phone number)

In order to send you correspondence in relation to

the services provided and to fulfil our regulatory and

compliance obligations.

Employment information, financial

information

In order to comply with KYC obligations and in order

to meet our regulatory obligations relating to

assessing the appropriateness of our products and

services.

Ethnicity, citizenship and social

security numbers or national

identity and passport

In order to comply with KYC and regulatory trade

reporting and other AML obligations.

Proof of photo ID, address

verification

In order to comply with KYC and regulatory trade

reporting and other AML obligations.

Unique device number (IP address)

and device information including

version of web browser you use

When you visit our website, navigate through the

pages or fill in any forms, we may collect your unique

device number or IP address in order to set up your

profile.

Financial sanctions and credit

header information

In order to perform our electronic AML screening

checks and to comply with other fraud detection

policies. This may generate further information on

your credit history, criminal convictions or political

interests leading to us making decisions based on the

results of these checks.

6. How we use your personal information

We use information held about you in the following ways:

• To ensure that the content in our website is presented to you in the most effective manner and to

improve the content of our website;

• To communicate with you and contact you and to provide you with products and services that you

request from us or, where you have considered to be contacted, for products and services that we feel

may be of interest to you;

• Managing and administering the products and services provided to you;

• Keeping you updated as a Client in relation to changes to our services and relevant matters;

• Provide, improve, test and monitor the effectiveness of our Services.

• Develop and test new products and features.

• Monitor metrics such as total number of visitors, traffic and demographic patterns.

• Diagnose or fix technology problems.

• To carry out our obligations arising from any contracts entered between you and us.

IC Markets Global – Privacy Policy January 2023 V:1.5 | 5

• We may also use your data, or permit selected third parties and our processors to use your data, to

provide you with information about goods and services which may be of interest to you and we or they

may contact you about these by email.

• To notify you about updates to the website.

• To send out newsletters or information about other opportunities that we believe will be of interest to

you. We will only send this to you if you have indicated that you wish to receive such information and

we will respect your wish not to do so if you communicate such wish to us. You can opt-out receiving

marketing communications at any time if you do not wish to receive such marketing material by clicking

on “unsubscribe” or by sending an email request to enquiries@icmarkets.com.

• To promote safety and security. We use the information we have to help verify accounts and activity,

and to promote safety and security on our regulated services, such as by investigating suspicious activity

or violations of our terms or policies. We work hard to protect your account using teams of IT specialists,

automated systems, and advanced technology such as encryption.

7. Who we share your personal information with?

We will not rent or sell your information to third parties outside of IC Markets Global (or the group of

companies of which IC Markets Global is part of) without your consent. We also impose strict restrictions on

how our processors can use and disclose the data we provide. Here are the types of third parties we share

information with:

• Service providers and other partners: We transfer information to service providers (processors), and

other partners who globally support our business, such as providing technical infrastructure services,

trading platforms analysing how our Services are used such as measuring the effectiveness of ads and

services, providing client service and support, client on-boarding, client identify verification, including

PEPs and sanctions, conducting marketing communications and design, services related to our website

management, services related to software and business development services.

We need to transfer personal data to recipients outside the European Union; these activities can include

dealings with foreign public entities (only when necessary and under request), the outsourcing of

services to external providers located outside the EU and/or processing the data outside the EU (i.e

cloud computing, client identity verification and individuals from outside the EEA accessing to our web-

services).

• Measurement and Analytics Services: Partners who use our analytics services like Google Analytics

(Non-Personally Identifiable Information Only). We do not share information that personally identifies

you (personally identifiable information is information like name or email address that can by itself be

used to contact you or identifies who you are) with advertising, measurement or analytics partners.

IC Markets Global does extensive due diligence before choosing processors assuring that they provide

sufficient safeguards, in particular in terms of expert knowledge, data governance, data security, cyber

resilience, reliability and resources to implement technical and organisational measures in such a manner

IC Markets Global – Privacy Policy January 2023 V:1.5 | 6

that processing will meet the requirements of General Data Regulation and ensure the protection of the

rights of the data subject.

The adherence of the processor to an SLA Contract is used as an element to demonstrate compliance with

the obligations of the controller.

The carrying-out of processing by our processor it is governed by a contract other legal act under Union or

Member State law, binding the processor to the controller.

This data sharing with our processor enables us to proceed with our regulated activities and duties to KYC in

order to meet our regulatory obligations relating to assess the appropriateness of our products and services,

provide support to clients, etc. Some of those third party recipients (processors) may be based outside the

European Economic Area; if the third party recipient is located outside the EU/EEA in a country not ensuring

an adequate level of data protection, the transfer will only be completed if a written agreement has been

entered into between IC Markets Global and the third party. The written agreement shall be based on the

Standard Contractual Clauses approved by the European Commission (and any updated versions). — for

further information including on how we safeguard your personal data when these cases occur, see

paragraph ‘Transfer of your information out of the EEA

We will share personal information with law enforcement or other authorities if required by applicable law.

8. Cookie Data

We use cookies and similar technologies to provide and support our Services. When you use our website we

will use cookies to distinguish you from other users of our website.

For more information about cookies and how we use them, please read our Cookies Policy.

9. How our global services operate

9.1 Transfer of your information out of the EEA

Information collected within the European Economic Area (“EEA”) will be transferred to countries outside of

the EEA for the purposes described in this policy and relying on the lawful basis of contractual necessity and

compliance with our legal obligations.

We and our processors when data is transferred outside the EEA utilise standard contract clauses approved

by the European Commission and we adopt other means under European Union law and may obtain your

consent to legitimise data transfers from the EEA to and other countries.

10. How do we respond to legal requests or prevent harm?

We access, preserve and share your information with regulators, law enforcement or others by request:

IC Markets Global – Privacy Policy January 2023 V:1.5 | 7

• We can respond to legal requests when we have a good-faith belief that the response is required by law

in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognised

standards.

• When we have a good-faith belief it is necessary to: detect, prevent and address fraud, unauthorised

use of the services or products, violations of our terms or policies, or other harmful or illegal activity; to

protect ourselves (including our rights, property or Products), you or others, including as part of

investigations or regulatory inquiries; or to prevent death or imminent bodily harm. For example, if

relevant, we provide information to and receive information from third-parties about the reliability of

your account to prevent fraud, abuse and other harmful activity on and off our Products.

Information we receive about you (including financial transaction as data related to deposits and

withdrawals) can be accessed and preserved for an extended period when it is the subject of a legal request

or obligation, governmental investigation, or investigations of possible violations of our terms or policies, or

otherwise to prevent harm. We also retain information from accounts disabled for terms violations for at

least a year to prevent repeat abuse or other term violations.

11. Your rights

Under the General Data Protection Regulation you have a number of important rights if you are resident

within the European Union. In summary, those include rights to:

• Fair processing of information and transparency over how we use your use personal information,

• The right to access personal data: via a Subject Access Request. Your request should be made in writing

to enquiries@icmarkets.com

• We may ask you for proof of identity before providing you with the data. There is usually no charge for

such requests, however in limited circumstances we may be able to charge an administrative fee (and

we will inform you in response to your request if that is the case).

• The right to request that your personal data is corrected if it is found to be inaccurate: require us to

correct any mistakes in your information which we hold.

• The right to request that your personal data is erased where it is no longer necessary. In some

circumstances this right may not apply e.g. if there is some other compelling reason for us to keep or

process your data (and we will inform you in response to your request if that is the case).

• Right to data portability: to receive the personal information concerning you which you have provided

to us, in a structured, commonly used and machine-readable format and have the right to transmit those

data to a third party (another controller) in certain situations.

• The right to withdraw consent to processing at any time, where relevant i.e. where we are relying on

your consent to process the data and not another legal reason for processing.

• The right to object at any time to processing of personal information concerning you for direct

marketing.

• The right not to be subject to a decision which is based solely on automated processing, including

profiling which produces legal effects concerning them or significantly affects them.

• The right to object in certain other situations to our continued processing of your personal information.

IC Markets Global – Privacy Policy January 2023 V:1.5 | 8

• Otherwise restrict our processing of your personal information in certain circumstances

If you would like to exercise any of those rights, please:

• email to us at enquiries@icmarkets.com

• let us have enough information to identify you (eg account number, username, registration details),

• let us have proof of your identity and address (a copy of your driving licence or passport and a recent

utility or credit card bill), and

• let us know the information to which your request relates, including any account or reference numbers,

if you have them.

If you would like to unsubscribe from any emailing or any marketing communications you can also click on

the ‘unsubscribe’ button at the bottom of the email or by sending an email at enquiries@icmarkets.com

stating so.

12. Legal basis for processing personal data

Reasons we can collect and use your personal information: Lawful basis for processing under EU data

protection law, there must be a lawful basis for all processing of personal data (unless an exemption or

derogation applies). We rely on:

• Contractual necessity Processing is necessary for the performance of a contract with the data subject

or to take steps to enter into a contract to conduct regulated activities, when processing is necessary

for the entry into, or performance of contract with the data subject or in order to take steps at this or

her request prior to the entry into a contract.

• Compliance with legal obligations Processing is necessary for compliance with our legal obligation. IC

Markets Global has the necessity for compliance with a legal obligation.

• Legitimate interest Data will only be processed where it is necessary for the purposes of the legitimate

interests pursued by IC Markets Global, and these interests or fundamental rights are not overridden by

the interests, rights and freedoms of the data subject and that the processing would not cause

unwarranted harm. For instance, it is a legitimate interest of IC Markets Global to process personal data

on data subjects in order to expand the business, develop new business relations prevention of fraud,

maintaining the security of our systems if/when necessary, enhancing, modifying or improving our

services. The data subject must be given information on the specific legitimate interest if a processing is

based on this provision.

13. Keeping your personal information secure

Your Data is stored and kept confidential according to the legislation on protection of personal data and

processing thereof applicable in the jurisdiction in which IC Markets Global with which you have signed up

is located.

We have appropriate security measures in place to prevent personal information from being accidentally

lost, misused, modification, disclosure or accessed in an unauthorised way. We limit access to your personal

IC Markets Global – Privacy Policy January 2023 V:1.5 | 9

information to those who have a genuine business need to know it. Those processing your information will

do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and

any applicable regulator of a suspected data security breach where we are legally required to do so.

14. How long your personal information will be kept

14.1 Data retention:

You can close your account any time, but for audit trail purposes, IC Markets Global shall hold personal data

for a period of at least five years after closing the account in order for us to comply with our record keeping

obligations under the Money Laundering Regulations 2020.

At the end of that period, we will delete all personal data relating to you, unless a legal requirement requires

them to keep the data for a prolonged period of time, or Data Subject has expressly consented to their data

being held for an extended period of time.

14.2 What happens in the event of a change of control?

If we sell or otherwise transfer part or the whole of IC Markets Global or our assets to another organization

(e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your

information such as name and email address and any other information collected through the Service may

be among the items sold or transferred. You will continue to own your User Content. The buyer or transferee

will have to honour the commitments we have made in this Privacy Policy.

14.3 How to complain?

We hope that our Data Protection Officer, client support or compliance team can resolve any query or

concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory

authority. In the Seychelles the Data Protection Act (the 'Act') was enacted in 2003 (Act No. 9 of 2003) with

the aim of protecting the fundamental privacy rights of individuals against the use of data concerning them

without their informed consent. The Act will come into operation on such date as the Minister notifies in the

official Gazette.

14.4 How to contact us?

If you wish to contact us with any queries, concerns or complaints, you can email us at

enquiries@icmarkets.com .

15. National requirements

IC Markets Global shall comply with both the GDPR and national data protection legislation.

IC Markets Global – Privacy Policy January 2023 V:1.5 | 10

If applicable national legislation requires a higher level of protection for personal data than such

policies/guidelines, such stricter requirements are to be complied with. If IC Markets Global

policies/guidelines are stricter than the local legislation, our policies/guidelines must be complied with.

16. Changes to this privacy notice

This privacy notice was published in May 2019 and last updated in November 2020.

We may change this privacy policy from time to time, when we will inform you via our Website or via email.

17. Do you need extra help?

If you would like this notice in another format (for example: audio, large print, braille) please contact us (see

‘How to contact us’ above).