Privacy Policy

Introduction

Focus on DOOEL Street 1615, No:20/A, floor 36, Apt 315, Aerodrom, Skopje, North Macedonia, Republic Of North Macedonia Your privacy is very important to us. We are committed to protecting and respecting your personal data. This Privacy Policy describes how and when we choose to use our services and how we will keep it safe, the types of personal data we collect about you. It also explains your rights regarding the processing of your personal information and how you will apply it. Please take the time to read and understand this policy. We may make changes to this notice from time to time and it is important that you check this update for any updates. The personal information we obtain is subject to our most up-to-date privacy statement. We think it is important if we make changes, we will forward them to you. Please note that this notification is given to customers and potential customers. If you are a Street 1615, No:20/A, floor 36, Apt 315, Aerodrom, Skopje, North Macedonia employee, a contractor, Focus on DOOEL or a third-party service provider, your personal information is your employment contract, contractual relationship or by contacting us will be used in accordance with our existing separate policies. In this privacy statement, references to "us", "our", "us" or "Focus on DOOEL" require context, unless otherwise stated, in Street 1615, No:20/A, floor 36, Apt 315, Aerodrom, Skopje, North Macedonia is a reference to each group company. Similarly, the references of "you", "your", "yours" or "yourself" in this privacy statement are any references to our customers and potential customers, as they require content unless otherwise specified. By accessing our website, including using any of the communication channels to communicate with us, you have read and understand the terms of this notification and consider how we process the information you have disclosed to us, including your personal data, before you become a customer. After opening an account with us, you agree to how we collect, store, use, share, and otherwise manage your personal data and rights, including any changes you make, during, and after our business relationship.

Who are we?

This privacy statement applies to the processing activities of the following data controller entities in the Focus on DOOEL group of companies: Focus on DOOEL Street 1615, No:20/A, floor 36, Apt 315, Aerodrom, Skopje, North Macedonia

What kind of personal information do we collect and store?

As part of our business, we collect personal data from customers and potential customers, including:

• name, surname and contact information

• date of birth and gender

• information about your income and wealth, including details about your assets and liabilities, account balances, transaction statements, tax, and financial statements.

• occupation and employment details

• location data

• knowledge and experience in the trade, risk tolerance, and risk profile

• IP address, device features, and other information about your trading experience

• bank account, e-wallet and credit card information

• the details of your visits to our Website or Applications are, but not limited to, traffic data, location data, blogs, and other communication data.

We use cookies to store and collect information about your use of our website. Cookies are small text files stored by the browser on your device's hard drive. When you enter our website, they send the information restored to our web server. These cookies allow us to adjust your personal settings and upload your personal preferences to improve your experience. You can learn more about our cookies on our "Cookies Policy" on our Website. We also keep records of your business behavior, including:

• products you trade with us

• historical data about your investments and investments, including the amount you invested

• your choice for certain products and services

If you are opening a new account or putting a new signature on an existing account, the law needs to foresee. Anti-money laundering laws require that we view and record the details of certain documents (photo and non-photographic documents) to meet the standards set by those laws. Identity documents required under money laundering legislation or other legislation related to the services we provide to you include:

(a) passport;

(b) driver's license;

(c) National identity document (if any);

(d) electricity bills;

(e) certificate of trust (if any);

(f) a credit check on the individual; or

(g) any other information it deems necessary for our functions and activities.

If you are a corporate customer, we need to collect additional information such as company addresses, shareholders, managers, officers, including additional personal information about shareholders and directors. We have the right to request additional information that it deems necessary to comply with our legal and regulatory requirements. We acquire this information in a variety of ways, using our services and websites, account opening practices, demo registration forms, webinar registration forms, website cookies and similar tracking technologies included in our Website and Applications. News updates and information provided during our current updates. We may also collect information about you by third party marketing lists, public sources, social media platforms, brokers and affiliates, bankers and credit card processors, subscription-based intelligence databases, and other third parties that you purchase from third parties partners. We may voluntarily request other personal information (for example, through market research, surveys, or special offers). If you do not choose to provide the information we need to fulfill your request for a particular product or service, we may not be able to provide you with the desired product or service. Regarding the services we provide to you and our relationship with you, we may record any communication with you or otherwise, electronically, by telephone. These records will be our sole property and will provide evidence of the communication between us. Such phone calls can be recorded without an alert tone or another alert. Also, if you visit any of our offices or facilities, we can have CCTVs that will record your picture.

Who can we disclose your personal information to?

As part of using your personal information for the purposes set out above, we may disclose your information to: Other companies that provide financial and other services within the Focus on DOOEL group; When you use our applications, communication systems and trading platforms offered to us by third parties, third-party application providers; contracted service providers and expert consultants to provide services such as administrative, IT, analytics and online marketing optimization, financial, regulatory, eligibility, insurance, research or other services; Introducing brokers and affiliates with which we have a mutual relationship; Payment service providers and banks that carry out your transactions; auditors or contractors or other consultants who audit, advise, or advise any of our business objectives; Our agreement with government agencies and law enforcement agencies where required by law, authorized courts, courts and related regulatory authorities, or where required by law and in response to other legal and regulatory requests; Any third party to which such disclosures are required to enforce or enforce our Terms of Service or other relevant agreements; Anyone empowered by you. We endeavor to disclose only the minimum personal data that these third parties need to fulfill their contractual obligations. Our third-party service providers are not permitted to share or use the personal data we provide to them for any purpose other than to provide services to us. Our websites or apps may contain links to external third-party websites. However, please note that third-party websites are not covered by this privacy statement and are not subject to our privacy standards and procedures. Please check with third parties' privacy practices and procedures.

When and how do we get your approval?

We may process your personal data for one or more legal action bases ("Legal Basis"), depending on the particular purpose for which we use your data. The legal basis is:

• fulfilling contractual obligations towards you

• comply with legal and regulatory requirements

• to follow our legitimate interests

If the use of your personal information does not fall under one of these three Legal principles, we must obtain your consent. This permission will be given freely by you, and you have the right to withdraw your consent at any time by using the contact information provided in this privacy statement or by contacting us by leaving the mailing list.

Management of personal information:

We are committed to protecting and protecting personal data and we will implement and maintain appropriate technical and institutional measures to ensure an appropriate level of security for the protection of personal data provided to us from accidental or illegal destruction, loss, alteration, unauthorized disclosure or access. to personal data transmitted, stored or otherwise processed. We have commissioned a Data Protection Officer to ensure that the management of personal information complies with this privacy statement and applicable legislation. Apart from the Focus on DOOEL Group, we are committed to respecting the right to privacy and to comply with all relevant data protection laws and privacy notices, which handle or receive personal information that accepts the privacy of this information. In short, the data protection measures we have are: we train our employees dealing with personal information based on the privacy of customer information and their privacy, which requires that our employees use passwords and two-factor authentication when accessing our system; We apply the walls of China, and employees can only access the personal data necessary for the purposes of the tasks they use. It implements data encryption technologies during data transfer in Internet transactions and client access codes transferred between firewalls, intrusion detection systems and networks that use virus scanning tools to protect against unauthorized people and viruses entering our system; using private secure networks or encryption when sending electronic data for outsourcing purposes; to implement a clean table policy in all facilities that are stored institutionally by us and all our relevant institutions and provide secure storage for physical records; and using physical and electronic devices, such as access cards, cameras, and guards, to protect against unauthorized access.

How do we store personal information and for how long?

We keep personal information in a combination with secure computer storage facilities and paper-based files and other records, and we take steps to protect the personal information we obtain from abuse, loss, unauthorized access, alteration, or disclosure. When we think that personal information is no longer needed, we will either remove details that will identify you or safely destroy records. However, we may need to keep records for a considerable time. For example, we are subject to investment services and money laundering laws that require us to keep copies and evidence of actions taken by us in relation to authentication, sources of income and sources of income, tracking transactions, phone, chat. and e-mail communications, orders, and trade history, and your complaints and records, we can show that we act in accordance with regulatory codes of conduct throughout the business relationship. These records must be retained for five years after our business relationship with You has ended, or for a longer period, if requested by our Organizers. When you stop receiving marketing communications, we will keep your information on our suppression list, as we know you don't want to receive these communications. The data we collect from you can be transferred and stored outside of the European Economic Area ("EEA"). It can also be processed by staff working outside the EEA, who work for us or for one of our suppliers or Affiliates. We will take all reasonable steps to ensure that your data is handled securely and in accordance with this Privacy Policy. When we transfer your data to other third parties outside the EEA, in some cases, we may rely on applicable standard contract terms, binding company rules, EU-US Privacy Shield, or other equivalent regulations. If you would like a copy of such arrangements, please contact us using the contact information below.

Your rights:

Please note that these rights do not apply in all circumstances. You have the right:

(a) request access to your personal data (commonly known as "data subject access request");

(b) requesting correction of the personal data we hold about you;

(c) requesting the deletion of your personal data. However, at your request, we may not always comply with your request for deletion, if possible, for certain legal reasons to be notified.

(d) Is there anything you want to object to processing on this ground when we think that your personal data is linked to a legitimate interest (or a third party) and is related to a particular situation and is affected? Your fundamental rights and freedoms. You also have the right to object to the places where we process your personal data for direct marketing. In some cases, we may demonstrate that we have legitimate reasons to process your information, which invalidates your rights and freedoms;

(e) requesting that the processing of your personal data be restricted. This allows you to request that we suspend the processing of your personal data in the following scenarios: If you want us to determine the accuracy of the data; The use of the data is unlawful, but you do not want us to delete it; where you should keep the data without having to hold the data unless you need to create, enforce or defend legal claims; or You have objected to our use of your data, but we need to verify that we have invalidated legal reasons to use it;

(f) To request the transfer of your personal data to you or a third party. We will present your personal data in a structured, widely used, machine-readable form to you or a third party of your choice. Note that this right applies only to automated information (for example, not too hard copies) that you consent to use for you, or that we use to make a contract with you; and

(g) Withdraw your consent at any time we consent to process your personal data.

We try to respond to all requests within 1 (one) month. Sometimes it may take longer than 1 (one) month if your request is particularly complicated or if you make a request. In this case, we will inform you within 1 (one) month of receipt of your request and keep you updated. We may charge a reasonable fee when a request is clearly baseless, excessive or repetitive, or when we receive a request to provide more copies of the same data. In this case, we will send you a fee request, which you must accept before we process your request. Alternatively, we may refuse to comply with your request in these cases.

What if you have a request or complaint?

We try to respond to all requests within 1 (one) month. Sometimes it may take longer than 1 (one) month if your request is particularly complicated or if you make a request. In this case, we will inform you within 1 (one) month of receipt of your request and keep you updated. If you are not satisfied with our response to your complaint, if you are a customer of ICB Capital or the Cyprus Data Protection Commissioner, you have the right to file a complaint with our Audit Authorities, Information Commission Office (ICO). The remaining ICB Capital Group is a customer of any of its assets. Alternatively, you have the right to complain to the data protection officer of your country of residence. You can find details on how to do this on the following websites: