Privacy Policy.

ASMX PRO (SEYCHELLES) LTD PRIVACY POLICY

This privacy policy governs the collection, storage and use of personal information by us on our website www.asmx.pro. It provides you with details about how your personal information is treated, your rights to that data, and how we use that data. By accessing our website and using the ASMX Platform, you agree to this privacy policy in its entirety. If you don't agree with this privacy policy as a whole or partially, you must not use the ASMX website or services.

This privacy policy was last updated on the 31st March 2025. Please check back regularly to keep informed of updates to this privacy policy.

We are the Data Controller and the Processor.

1. Who we are

AMSX Pro (Seychelles) Ltd is a company incorporated in the Seychelles, whose registered number is 8431951-1 and whose registered office is F20, 1st Floor, Eden Plaza, Eden Island, Seychelles.

ASMX Pro (Seychelles) Ltd was licensed by the Seychelles Financial Services Authority on 17 April 2024 under number SD191.

We respect your right to privacy and will only process personal information you provide to us in accordance with the principles of the Data Protection Act 2023 and other applicable privacy laws.

If you have any questions about how we collect, store and use personal information, or if you have any other privacy-related questions, please do contact us on the ASMX website www.asmx.pro or via trading@asmx.pro.

2. Site Users specific information

If you are applying to be a user of the website then this section explains the type of personal information we collect about you and how we may store, use and disclose your information.

2.1 The personal information we collect about you

(a) When you access, browse this website, submit personal information or apply to be a user of this website and while you continue to be a user of this website we will collect information from you which will include:

• (i) your name
• (ii) your current and previous postal addresses
• (iii) your phone and e-mail details
• (iv) your bank or building society account details to make transfers on the website
• (v) your date of birth
• (vi) your passwords and security question answers
• (vii) comments you make on blogs and discussion forums on the website
• (viii) correspondence with us by email and post
• (ix) answers to questions required by our KYC/AML provider for identification purposes
• (x) data about your activities using the website

(b) If you give us false or inaccurate information and we suspect or identify fraud, we will record this.

(c) If false or inaccurate information is provided and fraud is identified, details may be passed to fraud prevention agencies.

(d) We may also collect anonymised data in order to analyse statistics for usage of the site, however this data will not carry any single user identification.

2.2 How we use your personal information

We will use your personal information for the following purposes:

• to verify your identity and conduct anti-money laundering, counter-terrorist financing, sanctions and fraud prevention checks;
• to assess your suitability and eligibility to use our services, including categorising you as a professional, institutional or qualified investor where applicable;
• to open, administer, operate and close your account on the ASMX Platform;
• to process your orders, instructions and transactions and to settle, clear and report on them;
• to provide you with the products, services, information and customer support you request;
• to communicate with you about your account, transactions, security alerts and changes to our terms or policies;
• to comply with our legal, regulatory, tax, accounting and reporting obligations, including disclosures to the Seychelles Financial Services Authority, MERJ Exchange and other competent authorities;
• to monitor, record and analyse communications and activity on our website and platform for quality, training, compliance and security purposes;
• to detect, investigate and prevent fraud, market abuse, money laundering and other unlawful activity;
• to manage, improve and develop our website, platform and services, including troubleshooting, testing and statistical analysis;
• to send you marketing communications about our services where you have consented or where we are otherwise permitted to do so by law; and
• to enforce or defend our legal rights and to deal with complaints and disputes.

2.3 Legal basis for processing

We rely on one or more of the following lawful bases when processing your personal information:

• Contract: processing is necessary to enter into or perform a contract with you (for example, to provide our brokerage and platform services).
• Legal obligation: processing is necessary to comply with laws and regulations applicable to us, including anti-money laundering, KYC and securities regulation.
• Legitimate interests: processing is necessary for our legitimate business interests, such as preventing fraud, securing our systems, improving our services and managing our business, provided those interests are not overridden by your rights.
• Consent: where required, we will obtain your consent, for example for certain marketing communications or cookies. You may withdraw consent at any time.

3. Sharing your personal information

We treat your personal information as confidential. We will only disclose it outside ASMX Pro (Seychelles) Ltd in the following circumstances:

• to our group companies, affiliates and related entities where necessary to provide our services to you;
• to MERJ Exchange and other regulated trading venues, clearing systems, custodians, settlement agents and registrars as required to execute, clear and settle your transactions;
• to our service providers and processors, including KYC/AML providers, identity verification services, IT and hosting providers, cloud infrastructure providers, communications providers, customer support tools, analytics providers and professional advisers (lawyers, auditors, accountants);
• to regulators, law enforcement, tax authorities, courts and other governmental bodies where we are legally required or permitted to do so;
• to fraud prevention agencies and credit reference agencies where appropriate;
• to any prospective buyer or successor of all or part of our business in connection with a merger, acquisition, reorganisation or sale of assets; and
• to any other third party where you have provided your consent.

All third parties who process personal information on our behalf are required to do so under written agreements and to apply appropriate security measures. We do not sell your personal information to third parties.

4. International transfers

Because we operate internationally and use service providers located in different countries, your personal information may be transferred to, stored in and processed in jurisdictions outside Seychelles, including jurisdictions which may not provide the same level of data protection as your home country.

Where we transfer personal information internationally, we take steps to ensure that appropriate safeguards are in place, including using contractual protections with the recipients and assessing the legal regime in the destination country, in line with the Data Protection Act 2023 and applicable laws.

5. Data retention

We will retain your personal information for as long as is necessary to fulfil the purposes for which it was collected, including to provide our services to you and to comply with our legal, regulatory, tax, accounting and reporting obligations.

As a regulated firm, we are generally required to retain client identification, account opening, transaction and communications records for a minimum of seven (7) years from the end of our relationship with you, and in some cases longer where required by law or to defend or pursue legal claims.

When personal information is no longer required, we will securely delete, anonymise or destroy it.

6. Security

We take the security of your personal information seriously. We maintain appropriate technical and organisational measures designed to protect personal information against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include access controls, encryption in transit, secure hosting environments, staff training and ongoing review of our security practices.

However, no method of transmission over the internet or method of electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security. You are responsible for keeping your account credentials confidential and for notifying us promptly of any suspected unauthorised use of your account.

7. Cookies and similar technologies

Our website uses cookies and similar technologies (such as pixels, tags and local storage) to ensure the website functions properly, to remember your preferences, to analyse traffic and to improve your experience.

We use the following categories of cookies:

• Strictly necessary cookies — required for the website to function, such as session and security cookies. These cannot be disabled.
• Performance and analytics cookies — help us understand how visitors interact with the website so we can improve it.
• Functional cookies — remember choices you make to provide a more personalised experience.
• Marketing cookies — used, where consented, to measure the effectiveness of our marketing activity.

You can control and delete cookies through your browser settings. Disabling certain cookies may impact the functionality of our website.

8. Your rights

Subject to applicable law, you have the following rights in relation to your personal information:

• Right of access: to request a copy of the personal information we hold about you.
• Right to rectification: to ask us to correct inaccurate or incomplete information.
• Right to erasure: to ask us to delete your personal information, subject to our legal and regulatory retention obligations.
• Right to restrict processing: to ask us to limit how we use your personal information in certain circumstances.
• Right to object: to object to processing based on our legitimate interests or for direct marketing.
• Right to data portability: to receive personal information you provided to us in a structured, commonly used and machine-readable format, where technically feasible.
• Right to withdraw consent: where we rely on your consent, to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: to complain to the Seychelles Data Protection Commissioner or other competent supervisory authority.

To exercise any of these rights, please contact us at trading@asmx.pro. We may need to verify your identity before responding and will respond within the timeframes required by applicable law.

9. Marketing communications

From time to time we may send you marketing communications about our products and services that we believe may be of interest to you, where we are permitted to do so by law. You can opt out of marketing communications at any time by clicking the unsubscribe link in any marketing email, or by emailing us at trading@asmx.pro. Opting out of marketing will not stop service-related and regulatory communications.

10. Third-party websites

Our website may contain links to third-party websites, applications or services. This privacy policy does not apply to those third parties and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third party before providing them with your personal information.

11. Children

Our services are not directed to children and we do not knowingly collect personal information from individuals under the age of 18. If you believe that a child has provided personal information to us, please contact us so we can take appropriate action.

12. Changes to this privacy policy

We may update this privacy policy from time to time to reflect changes in our practices, technology, legal requirements or for other operational reasons. The latest version will always be available on our website and the "last updated" date at the top will be revised accordingly. We encourage you to review this policy periodically.

13. Contact us

If you have any questions, requests or complaints about this privacy policy or our use of your personal information, please contact us: