Protecting the privacy and safeguarding the personal and financial information of our clients and website visitors is one of our highest priorities and rhymes with our value of customer satisfaction. The following Privacy Policy explains how we collect and protect your information.

Any reference to ‘us’, ‘our‘, ‘we’ or ‘INGOT’ in this Privacy Policy is a reference to INGOT Financial Brokerage Ltd.

By opening an account or by using our website, you give your consent to the collection, use and disclosure of personal information by us as explained in this Privacy Policy.

1. Why we use your personal information

(a) We collect personal information when it is reasonably necessary for one or more of our functions and activities. These include:

I. Providing you with the products and services you ask for, and unless you tell us otherwise, to provide information on products and services offered by us and external product and service providers for whom we act as agent. If you have provided us with your email address or mobile phone details, we may provide information to you electronically with respect to those products and service;

II. Verifying your identity;

III. Complying with our legal obligations;

IV. Providing you with technical support;

V. Participating in any third-party acquisition or potential acquisition of an interest in us or our asset; and

VI. Taking measures to detect and prevent frauds, crime or other activity which may cause harm to our business or our products and services.

(b) We may collect information about you because we are required or authorised by law to collect it. For example, we require personal information to verify your identity under anti-money laundering and counter-terrorism financing (AML/CTF) regulations and other regulatory laws.

(c) We may also use your personal information for the future planning of our business, including product development, research and enhancing our customer service and providing you information on any opportunities that we believe may be relevant to you.

(d) In such instances outlined above, and in instances where we have legal or regulatory obligations, and depending upon particular restrictions, you consent to the disclosure of your personal information where we disclose that information to:

I. Relevant regulators or government authorities as required, authorised, permitted or compelled by law;

II. Where applicable, anyone authorised by you, for example, your financial adviser;

III. Sub article deleted; and

IV. Third party service providers, including those who help facilitate or support our business, or develop new software to run our business more efficiently, these could include specialist advisers who have been contracted to provide us with administrative, IT, financial, regulatory, compliance, taxation, insurance, research or other services.

(e) Where we share your personal information in the ways set out above, you acknowledge and understand that this may result in your personal information being sent outside of the Hashemite Kingdom of Jordan. Where this occurs, while we make reasonable attempts to protect the personal information that you share with us, you acknowledge that we may not be able to extract an undertaking from the overseas recipients that they will comply with privacy laws and the ability to enforce privacy laws or any other contractual privacy obligation in relation to any breach may be very limited. As such, we will not be accountable for any breaches of those laws by that overseas recipient.

Because privacy laws may not apply or be enforceable against some overseas recipients, we understand that you may choose not to disclose your personal information to us. However, if you choose not to provide the information, we may not be able to open your trading account or provide you with the product or service that you have requested.

2. The types of personal information we collect

We only collect personal information that is reasonably necessary for one or more of our functions or activities. The types of personal information we collect and hold directly from you includes your name, residential and mailing address, telephone number, e-mail address, bank account details and other information which could be used to identify who you are, for us to provide our products and services to you, and to comply with anti-money laundering and counter-terrorism financing (AML/CTF) laws and regulations. We also collect demographic information, including date of birth, education and occupation. We also assess your trading experience, your approximate annual income and approximate net worth to assess your financial position.

3. How we collect and hold personal information

(a) We must collect your personal information only by lawful and fair means. Before and at the time of collecting personal information, we will obtain your consent for the purposes for which we intend to use and disclose your personal information.

(b) Having provided consent, you are able to withdraw it at any time. To withdraw consent, please contact us. Please note we may not be able to provide you with our services if you provide incomplete or inaccurate information, or if you withdraw your consent to use this information.

(c) We obtain most of the information directly from you through your application forms, telephone conversations and from maintaining records of information obtained in the course of ongoing customer service. We may also obtain information from other sources, including credit reference agencies, analytics providers, search information providers and through publicly available sources.

(d) We may also obtain information about you through your use of our websites, apps or through the use of cookies on our websites.

(e) We may also ask for other information voluntarily, including through market research, surveys or special offers, so that we can improve our service or better cater to the wider needs of our current and future clients.

(f) We may record communications that we have with you in relation to the services we provide to you and our relationship with you. These recordings may be in electronic format, by telephone, in person or otherwise and will be our sole property, constituting evidence of the communications between us. Such telephone conversations may be recorded without the use of a warning tone or other notice.

(g) We will do all that we can to ensure that the personal information that we collect, use and disclose is accurate, up-to-date, complete and relevant.

3.1 Dealing with unsolicited information

(a) If we receive personal information that is not solicited by us, we will only retain it, if we determine that it is reasonably necessary for one or more of our functions or activities, and that you have consented to the information being collected or given the absence of your consent that it was impracticable or unreasonable for us to obtain it under the circumstances.

(b) If these conditions are not met, we will destroy or de-identify the information.

3.2 Aggregated data

(a) Aggregated data is general data about groups of people which does not identify anyone personally, for example the number of people in a particular industry that engage in derivative trading. We use aggregated data to:

I. help us to understand how you use our products and services and improve your experience with us; and

II. customise the way that we communicate with you about our products and services so that we can interact with you more effectively.

(b) We may share aggregated data with our business or industry partners.

3.3 Article deleted.

3.4 Record keeping

Please note under the AML/CTF regulations and policies, we are required to retain customer identification records and transaction records for at least five years after we have stopped providing our services to you.

Notifying you

(a) When we receive personal information from you directly, we will take reasonable steps to notify you how and why we collected your information, who we may disclose it to and outline how you can access it, seek correction of it or make a complaint.

(b) Sometimes we collect your personal information from third parties. You may not be aware that we have done so. If we collect information that can be used to identify you, we will take reasonable steps to notify you of that collection.

Who we may communicate with

(a) Depending on the product or service you have, the entities we exchange your information with include but are not limited to:

I. Broker and agents who refer your business to us;

II. affiliated product and service providers and external product and service providers for whom we act as agent, so that they may provide you with the product or service you seek or in which you have expressed an interest;

III. auditors we appoint to ensure the integrity of our operations;

IV. any person acting on your behalf, including your solicitor, settlement agent, accountant, executor, administrator, trustee, guardian or attorney;

V. your referee (to confirm details about you);

VI. if required or authorised to do so, regulatory bodies and government agencies;

VII. credit reporting agencies;

VIII. insurers, including proposed insurers and insurance reference agencies, where we are considering whether to accept a proposal of insurance from you and, if so, on what terms;

IX. other financial institutions and organisations at their request if you seek credit from them, so that they may assess whether to offer you credit;

X. investors, advisers, trustees and ratings agencies where credit facilities and receivables are pooled and sold (securitised);

XI. other organisations and associations who in conjunction with us provide products and services so that they may provide their products and services to you; and

XII. professional associations or organisations with whom we conduct an affinity relationship to verify your membership of those associations or organisations.

(b) Our use or disclosure of personal information may not be limited to the examples above.

(c) We may be required to disclose customer information by law e.g. under Court Orders or Statutory Notices pursuant to taxation or social security laws or under laws relating to sanctions, anti-money laundering or counter-terrorism financing.

3.5 Outsourcing

(a) We disclose personal information when we outsource certain functions, including bulk mailing, card and cheque book production, market research, direct marketing, statement production, debt recovery and information technology support. We also seek expert help from time to time to help us improve our systems, products and services.

(b) We use banking agents, for example, local businesses, to help provide you with face-to-face banking services. These agents collect personal information on our behalf.

(c) In all circumstances where personal information may become known to our contractors, agents and outsourced service providers, there are confidentiality arrangements in place. Contractors, agents and outsourced service providers are not able to use or disclose personal information for any purposes other than our own.

(d) We take our obligations to protect customer information very seriously; we make every effort to deal only with parties who share and demonstrate the same attitude.

4. Our affiliates and partners

We may share information with affiliates if the information is required to provide the product or service you have requested or to provide you the opportunity to participate in the products or services our affiliates offer. We may also forge partnerships and alliances, which may include joint marketing agreements, with other companies who offer high-quality products and services that might be of value to our clients. In order to ensure that these products and services meet your needs and are delivered in a manner that is useful and relevant, we may share some information with partners, affiliates and alliances. This allows them to better understand the offers that are most relevant and useful. The use of your personal information is limited to the purposes identified in our relationship with the partner or affiliate.

We do not sell, license, lease or otherwise disclose your personal information to any third party for any reason, except as described in this Privacy Policy. We reserve the right to disclose your personal information to third parties where required by law to regulatory, law enforcement or other government authorities. We may also disclose your information as necessary to credit reporting or collection agencies, or when necessary to protect our rights or property.

To help us improve our services to you, we may engage another business (which may be located overseas) to help us to carry out certain internal functions such as account processing, fulfilment, client service, client satisfaction surveys or other data collection activities relevant to our business.

We may also provide a party with client information from our database to help us to analyse and identify client needs and notify clients of product and service offerings. Use of the information shared is strictly limited to the performance of the task we request and for no other purpose. All third parties with which we share personal information are required to protect personal information in a manner similar to the way we protect personal information.

5. Your rights

5.1 Access

(a) We will always give you access to your personal information unless there are certain legal reasons why we cannot do so. we do not have to provide you with access to your personal information if:

(i) We believe there is a threat to life or public safety;

(ii) there is an unreasonable impact on other individuals;

(iii) the request is frivolous;

(iv) the information wouldn’t be ordinarily accessible because of legal proceedings;

(v) it would prejudice negotiations with you;

(vi) it would be unlawful;

(vii) it would jeopardise taking action against serious misconduct by you;

(viii) it would be likely to harm the activities of an enforcement body (e.g. the police); or

(ix) it would harm the confidentiality of our commercial information.

(b) If we cannot provide your information in the way you have requested, we will tell you why in writing. If you have concerns, you can complain by contacting us on +962 6 588 5260 or you can send us an email to customerservice@INGOTBrokers.com.jo

5.2 Correction

(a) If you believe that is something wrong with the information, for example if you think that the information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, please update your details via the Traders’ Hub or contact us via customerservice@INGOTBrokers.com.jo so we can update your details.

(b) If we refuse to correct the personal information as requested by you, we will give you a written notice setting out the reasons for the refusal, the mechanisms available to complain and any other relevant information.

(c) If you are worried that we have given incorrect information to others, you can ask us to tell them about the correction. We will correct this if we can or we will notify you if we are unable to change the details.

(d) You can ask us to access your personal information that we hold by sending us an email to customerservice@INGOTBrokers.com.jo

(e) We will give you access to your information as soon as possible in the form you want it where it is reasonable and practical to do so. We will endeavour to comply with your request within fourteen (14) days of its receipt, but if that deadline cannot be met owing to exceptional circumstances, your request will be dealt with within thirty (30) days. To facilitate to provide access to you, please inform us of your needs.

(f) We are required to help you ask for the information to be corrected if we cannot correct this for you. Accordingly, we may need to talk to third parties. However, the most efficient way for you to make a correction request is to send it to the organisation which you believe made the mistake.

(g) If we are able to correct the information, we will notify you within five (5) business days of deciding to do this. We will also notify the relevant third parties as well as any others you notify us about. If there are any instances where we cannot do this, then we will notify you in writing.

(h) If we are unable to correct your information, we will explain why in writing within five (5) business days of making this decision.

(i) If we agree to correct your information, we will do so within thirty (30) days from when you asked us, or a longer period as agreed between us and you.

(j) If we are unable to make corrections within a thirty-day time frame or the agreed time frame, we must notify you of the delay, the reasons for it and when we expect to resolve the matter, ask you to agree in writing to give us more time.

5.3 Request to erase your personal data

You may request us to delete or remove personal data where there is no good reason for us to process it. Note, however, that 1) we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request; and 2) we may not be able to continue providing our services to you if you request for your personal data to be erased.

6 Integrity of your personal information

6.1 Quality of your personal information

(a) We ensure that the personal information we collect and use or disclose is accurate, up to date, complete, and relevant.

(b) Please contact us if any of the details you have provided to us change or if you believe that the information we have about you is not accurate or up to date.

(c) We may also take steps to update personal information we hold, for example, an address, by collecting personal information from publicly available sources such as telephone directories or electoral rolls.

6.2 Security of personal information

(a) We are committed to protecting any personal information we hold about you from misuse, interference, loss, unauthorised access, modification and disclosure.

(b) For this purpose we have a range of practices and policies in place to provide a robust security environment. We ensure the on-going adequacy of these measures by regularly reviewing them.

(c) Our security measures include, but are not limited to:

I. educating our staff as to their obligations with regard to your personal information;

II. requiring our staff to use passwords when accessing our systems;

III. encrypting data sent from your computer to our systems during Internet transactions and customer access codes transmitted across networks;

IV. employing firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses from entering our systems;

V. using dedicated secure networks or encryption when we transmit electronic data for purposes of outsourcing;

VI. providing secure storage for physical records; and

VII. employing physical and electronic means such as alarms, cameras and guards (as required) to protect against unauthorised access to buildings.

(d) Where information we hold is identified as no longer needed for any purpose we ensure it is effectively and securely destroyed, for example, by shredding or pulping in the case of paper records or by degaussing (de-magnetism of the medium using alternating electric currents) and other means in the case of electronic records and equipment.

7. Dealing with INGOT online

Your account information is password protected and you must not divulge your password to anyone. To further protect your personal information, your log-in time will automatically expire after a certain period of inactivity. INGOT cannot guarantee or accept responsibility for the privacy practices or the content of websites to which we provide links.

8. Other countries

(a) You acknowledge that it may be necessary for your information to be transferred to organisations who provides a service to us outside of the Hashemite Kingdom of Jordan, and you consent to such transfer.

(b) We may store your information in cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from various countries via an internet connection, it is not always practicable to know in which country your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed.

(c) Overseas organisations may be required to disclose information we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.

(d) By using our services, you are consenting to the disclosure of your information as described in this Clause 8. However, you may withdraw consent at any time by contacting our office, however this may mean we may be unable to continue providing you with our services if you withdraw your consent.

9. Restriction of responsibility

We are not responsible for the privacy policies or the content of sites we link to and have no control of the use or protection of information provided by you or collected by those sites. Whenever you elect to link to a co-branded website or to a linked website, you may be asked

to provide registration or other information. If at any time you choose to purchase a product or service offered by another company, any personal information you share with that company will no longer be controlled under our Privacy Policy.

Please note that the information you are providing is going to a third party and you should familiarize yourself with the privacy policy provided by that third party.

10. Use of (cookies)

We use cookies to assist us in securing your trading activities and to enhance the performance of our website. (Cookies are small text files sent from the Web server to your computer.) Cookies used by us do not contain any personal information nor do they contain account or password information. They merely allow the site to recognize that a page request comes from someone who has already logged on. We may share website usage information about visitors to the website with reputable advertising companies for targeting our Internet banner advertisements on this site and other sites. For this purpose, pixel tags (also called clear gifs or web beacons) may be used to note the pages you've visited. The information collected by the advertising company through the use of these pixel tags is not personally identifiable. To administer and improve our website, we may use a third party to track and analyse usage and statistical volume information, including page requests, form requests, and click paths. The third party may use cookies to track behaviour and may set cookies on behalf of us. These cookies do not contain any personally identifiable information.

11. Direct Marketing

We may use your personal information to offer you products and services that we believe may interest you. You will be receiving emails from us; if you do not wish to receive marketing offers from us, you can let us know by emailing us at customerservice@INGOTBrokers.com.jo We do not provide your personal information to other organizations for the purposes of direct marketing.

12. Government Identifiers

(a) Sometimes we may be required to collect government-related identifiers such as your tax file number.

(b) We will not use or disclose this information unless we are authorized or required to do so by law or the use of the government-related identifier is reasonably necessary for us to verify your identity for the purposes of our business activities or functions.

13 Website Changes to this Privacy Policy

From time to time, we may update this Privacy Policy. In the event we materially change this Privacy Policy, the revised Privacy Policy will promptly be posted to our website and we will post a notice on our website informing you of such changes.

You agree to accept posting of a revised Privacy Policy electronically on the website as actual notice to you. Any dispute over our Privacy Policy is subject to this notice and our Customer Agreement. We encourage you to periodically check back and review this policy so that you always will know what information we collect, how we use it, and to whom we disclose it. If you have any questions that this policy does not address, please contact at customerservice@INGOTBrokers.com.jo

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