Privacy Policy - Verte Securities Limited

Introduction

This Privacy Policy outlines how Verte Securities Limited ("Company," "We") collects, uses, discloses, shares, and protects your personal information (including any personal data) when you access and use the Stockity Trading Platform via the official website stockity.com (hereinafter referred to as "Website"), the Stockity Mobile Application, and/or other services provided by us. For the purposes of this Privacy Policy, all references to the Website and Stockity Mobile Application are considered equivalent and interchangeable. We respect your privacy and are committed to protecting the privacy of our users ("user" or "you"). This Privacy Policy outlines our practices regarding the collection, use, and disclosure of your information through the use of our Website, Stockity Mobile Application, and other online platforms we use to provide our services (collectively, "Services").

This Privacy Policy is an integral and legally binding part of the Stockity Client Agreement and applies to all users who register on the Website or use the Stockity Mobile Application, regardless of their geographic location. By registering an Account, logging into the Website or Stockity Mobile Application, or using any part of our Services, you confirm that you have read carefully, understood, and fully agree to all the terms and conditions set out in this Privacy Policy without any conditions.

The data you provide is collected and processed by Verte Securities Limited, a company established and operating under the laws of the Republic of Vanuatu, with company number 700726, and registered address at Level 1, ICount House, Kumul Highway, Port Vila, Vanuatu, which is the data controller responsible for ensuring that your personal data is processed in accordance with applicable data protection laws.

We are committed to maintaining the confidentiality, security, and integrity of all personal data you entrust to us. We implement all reasonable and necessary technical, organizational, and legal measures to protect your information from unauthorized access, alteration, disclosure, or destruction.

We strongly encourage you to read this Privacy Policy carefully before using the Website, Stockity Mobile Application, or our Services. If you do not agree with any provision in this Privacy Policy, you should stop using the Stockity Trading Platform. However, by continuing to use the Website, Stockity Mobile Application, or our Services, you acknowledge and consent to the collection, use, and processing of your data as described herein. All terms used in this Privacy Policy will be interpreted based on the definitions provided herein (if available). If no definition is provided in this Privacy Policy, the terms will be interpreted according to the definitions and provisions set forth in the Stockity Client Agreement.

1. Provision of Information About You

1.1 User Registration and Provision of Personal Data

When creating an Account on the Website or accessing the Stockity Mobile Application, you will be asked to provide an active and valid email address, required for initial registration and communication related to the provision of our Services. After registration, you may, at your discretion, voluntarily provide additional personal information by completing your profile in the Personal Account section on the Website or Stockity Mobile Application. This information may include your first and last name, date of birth, gender, contact phone number, and country of residence. This information allows us to personalize your user experience, facilitate secure access to the Stockity Trading Platform, and ensure accurate identification for operational and legal compliance purposes.

1.2 Provision of Payment and Identification Data

To open an Account and access certain services on the Stockity Trading Platform, you will be required to provide specific payment-related information, including:

• Full legal name;
• Bank card number;
• Card expiration date;
• Card verification code (CVV/CVC);
• Issuing bank or financial institution details;
• Payment system type (e.g., Visa, MasterCard);
• Passport or national ID number;
• Date of birth;
• Residential address;
• Valid email address;
• Active phone number;
• Other data depending on the payment method.

The information listed above is necessary for both the proper execution of financial operations and to ensure compliance with regulatory requirements, including but not limited to anti-fraud mechanisms, anti-money laundering (AML), and counter-terrorism financing (CTF) standards. This data must be complete, accurate, and verifiable. When processing these payment operations, we may also share and verify the necessary payment data through our official and trusted Payment System Providers, acting as either a data processor or independent controller depending on the specific operation. These providers may collect, process, and temporarily store information related to your transactions in accordance with applicable legal requirements, contractual obligations, and privacy standards. At the explicit request of the payment provider, we may be legally required to provide additional information about you, including scanned copies of identity documents and your contact details. Data storage is strictly limited to the duration necessary to process transactions, unless an extension is required by law. All such partners are obligated to comply with internationally recognized data protection frameworks and implement robust technical and organizational safeguards to ensure the security and confidentiality of your personal and financial information.

1.3 Identity Verification and Compliance with AML/CTF Requirements

To meet legal obligations related to anti-money laundering (AML), counter-terrorism financing (CTF), and Know Your Customer (KYC) requirements, we require you to complete the verification process. This process involves the mandatory submission of the following documents and data:

• Clear and readable photo or scan of a valid identity document (passport or national ID);
• Front and back photo of the payment card used for transactions and/or screenshot of your e-wallet;
• Selfie holding your identity document and payment card.

In certain cases, and if required by applicable law, you may also be asked to provide additional documents, including but not limited to:

• Recent utility bill containing your name and address;
• Reference letter from a licensed banking institution;
• Bank statement showing your name and transaction history;
• Official documents verifying the source of your funds or assets (e.g., employment contract, property sale agreement, loan agreement, or inheritance documents);
• Secondary identification documents (e.g., driving license or national ID).

All information and documentation submitted for verification purposes must be original, current, and verifiable. The collection and processing of this data are limited to what is necessary to meet our legal obligations under applicable AML/CTF laws and to maintain the integrity of the Stockity Trading Platform.

1.4. Collection of User Activity and Interaction Data

During your use of the Stockity Trading Platform, we collect and store various types of data related to activities that help us operate, secure, and improve our Services. This includes, but is not limited to:

• Records of login attempts and session activity;
• Registration date and account category;
• IP address history and type of device used to access the Stockity Trading Platform;
• Interface preferences, selected language, and time zone;
• Browser type and version;
• Frequency and nature of interactions within the Stockity Trading Platform, including trading activity and use of tools or services.

We also collect statistical and diagnostic information, including:

• Error logs and performance data;
• Clickstream behavior and in-app interactions;
• Transaction history and complaints;
• Records of communication with our support team.

This information is used to maintain the functional stability of the Stockity Trading Platform, troubleshoot technical issues, prevent unauthorized access or fraudulent behavior, enhance user experience, and comply with legal and regulatory obligations.

1.4.1. Participation in Promotions and Reward-Based Activities

If you participate in promotional campaigns or reward-based activities, you may be required to provide your full name, postal address, and phone number for the delivery of any prize or reward. We may also send promotional gifts or branded merchandise as part of marketing activities, loyalty programs, or user engagement strategies. In such cases, you must provide the same data: full name, valid shipping address, and contact phone number. This data is used solely for accurate and timely delivery and processed in accordance with this Privacy Policy.

We may send these items directly or through selected logistics providers. Where applicable, only the minimum personal data required will be transferred to these partners to enable delivery. You acknowledge and consent to such limited disclosures as necessary for marketing and customer retention activities.

1.4.2. Surveys and Feedback

We may invite you to voluntarily complete surveys or service evaluations, which may request your name and contact details for feedback purposes.

1.4.3. Support Services

If you contact our Support Services, you will be asked to provide a valid full name and email address so our team can provide timely and accurate responses. All communications may be recorded and stored for quality assurance, dispute resolution, and compliance purposes.

1.5. Cookies and Tracking Technologies

In accordance with standard industry practices, we use Cookies and similar tracking technologies to support the functionality and performance of the Stockity Website and Mobile Application. "Cookies" are small data files stored on your device when you visit or interact with our Services. These technologies allow us to recognize your device, remember your preferences, and improve your overall experience on the Stockity Trading Platform.

Some Cookies are strictly necessary for the Website to function correctly and are used without prior consent. These include:

• Cookies required to identify the source of your access to the Website;
• Cookies used to maintain session identity during navigation;
• Cookies storing technical preferences, such as language and time zone.

1.5.1. Usage Data

As part of using these technologies, we also collect and analyze Usage Data, including:

• IP address;
• Session identifiers;
• Device type and operating system;
• Browser type and version;
• Time zone and language settings;
• Access timestamps;
• URL or referral source directing you to our Website.

This data is essential to ensure a safe, stable, and personalized user experience, detect anomalies, enhance service responsiveness, and optimize performance. If you choose to disable or restrict Cookies in your browser settings, some features of the Stockity Trading Platform may not be accessible or function properly.

2. Legal Basis for Processing Your Information

2.1. Lawful Grounds

We collect and process your personal data only if there is a valid legal basis to do so, fully complying with applicable data protection laws and regulations. The legal bases we rely on include:

• Performance of a Contract: Processing is necessary to fulfill and execute the agreement between you and us, including but not limited to the Stockity Client Agreement, and to provide our Services as requested through your registration or ongoing use of the Stockity Trading Platform.

• Consent: You have expressly provided consent for the collection and use of your personal data. This consent is obtained during registration, including through acceptance of the Stockity Client Agreement and this Privacy Policy.

• Legal Compliance: Processing is necessary for us to comply with legal or regulatory obligations imposed by applicable law, including anti-money laundering (AML), counter-terrorism financing (CTF), tax, accounting, or financial regulations.

• Legitimate Interests: Processing is necessary to pursue our legitimate business interests, such as fraud prevention, optimization of the Stockity Trading Platform, service improvement, or internal reporting. In all cases, we ensure your rights and freedoms are not overridden and that a fair balance is maintained between our interests and your data privacy.

2.2. Implications of Withholding Data

Please note that if you choose not to provide certain essential personal data or withdraw previously given consent when it is the only legal basis for processing, we may be unable to provide the requested services or maintain the functionality of your Personal Account. We will inform you of these implications at the relevant time.

3. Storage of Your Information

3.1. Retention Periods

We store your personal data only as long as necessary to fulfill the purposes for which it was collected, as outlined in this Privacy Policy, including compliance with laws, regulations, and agreements. Specific retention periods may vary depending on the nature of the data, the context of collection, and applicable legal requirements.

Your personal data may be retained for the following reasons:

• To comply with obligations arising from applicable laws and regulatory frameworks (e.g., anti-money laundering laws, financial reporting, tax laws);
• To support the performance and enforcement of agreements made with you, including the Stockity Client Agreement;
• To resolve disputes, investigate incidents, or handle user complaints;
• To maintain historical business and operational records, if permitted by law;
• To protect our legitimate interests, including fraud prevention and security monitoring.

Once the data is no longer required for the purposes outlined above, or if retention is no longer required under applicable law, the data will be securely deleted, anonymized, or otherwise disposed of in accordance with recognized data protection standards.

If there is a statutory retention obligation or if the data is needed to assert, exercise, or defend legal claims, we will retain the data accordingly and limit its processing to specific purposes.

4. PURPOSES OF PROCESSING YOUR INFORMATION

4.1. Primary Purposes

The personal data we collect is used to ensure the smooth operation of the Stockity Trading Platform, improve the quality of our existing services, and develop new services. The main purposes for processing your data include, but are not limited to, the following:

1. Providing you with high-quality and secure services on the Stockity Trading Platform, including seamless technical functionality, system performance monitoring, identification of technical errors, and improving the stability and responsiveness of our Services across all devices;

2. Enhancing the convenience and efficiency of the Stockity Trading Platform through the use of Cookies and similar technologies that track interface usage, device type, IP address, session data, and language preferences, helping us deliver content in the most suitable format and language for your region and device;

3. Storing and utilizing data collected from your initial visit and any subsequent sessions on the Website to support continuity of your interaction with the Stockity Trading Platform, including remembering login credentials, previously selected options, and personalized interface settings;

4. Using registration and identity verification data (such as your first and last name, middle name if any, gender, date of birth, nationality, and contact information) to verify your identity, maintain the accuracy of your Personal Account, and ensure that the services we provide are tailored to your needs and comply with applicable regulations;

5. Ensuring legitimate and secure transactions by verifying the accuracy of financial documents you submit, checking consistency between registration information and payment instruments, and screening for fraudulent or illegal activity in accordance with international standards and our internal compliance procedures;

6. Facilitating deposits and other financial transactions by storing non-sensitive data (excluding your card number, expiration date, CVC/CVV code, or any confidential banking credentials), and using this data to streamline future interactions with the Stockity Trading Platform by auto-filling previously provided payment details, where allowed and applicable;

7. Collecting and reviewing records of your financial and operational activity on the Stockity Trading Platform, including transaction logs, IP addresses, access timestamps, and device/browser details, to ensure fund security, enforce fraud detection mechanisms, and comply with anti-money laundering (AML) policies;

8. Sending system-generated notifications regarding operational matters (such as maintenance periods, Platform updates, or service feature modifications), and distributing personalized advertising and promotional content to you via email, SMS, phone calls, and other legally permitted communication channels. You have full control over receiving these messages and can unsubscribe from promotional communications at any time through your Personal Account settings or by contacting Support;

9. Communicating with you regarding operational changes to the Website, updates to our Services, amendments to this Privacy Policy or the Stockity Client Agreement, or the implementation of new regulatory obligations. Such messages are considered important communications and may not always be subject to unsubscribe options;

10. Providing a personalized user experience by adapting Website content and marketing campaigns based on your activity, preferences, behavior patterns, and device data to show you more relevant offers and enhance your satisfaction with our Services;

11. Responding effectively to support requests, inquiries, or complaints by collecting, storing, and reviewing relevant communication logs and data to ensure proper documentation and timely resolution.

4.2. Additional Processing

If we intend to use your personal data for purposes not explicitly described above, we will first obtain your explicit and clear consent. Furthermore, if personal data processing is carried out automatically, we ensure that it does not result in any decision with legal effects or significantly impact you, unless adequate safeguards are in place.

5. DISCLOSURE OF YOUR INFORMATION

5.1. Circumstances for Disclosure

We may disclose your personal data only if necessary and in accordance with this Privacy Policy and applicable legal framework. Disclosure of personal data may occur in the following circumstances:

• Business Transfers: If the Company is involved in any corporate transaction, including but not limited to mergers, acquisitions, restructurings, or asset sales, your personal data may be disclosed or transferred to another entity as part of the transaction. In such cases, we will take reasonable steps to ensure that the acquiring party adheres to data protection standards consistent with this Privacy Policy. You will be notified if your data will be subject to a different privacy policy before such a transfer.

• Legal Obligations and Law Enforcement: We may disclose your personal data if required by applicable law or in response to a lawful request from government authorities, courts, regulators, or law enforcement agencies. This includes compliance with obligations under anti-money laundering (AML), financial crime, or counter-terrorism financing (CTF) laws.

• Protection of Legal Interests and Security: We may disclose personal data when necessary, in our reasonable judgment and good faith, to:

  1. Comply with legal obligations or enforce applicable laws and regulations;
  2. Protect and defend the rights, property, or legal interests of the Company, our users, or affiliates;
  3. Prevent or investigate suspected violations of the Stockity Client Agreement or other unlawful conduct;
  4. Protect the safety and personal interests of clients, employees, or the public;
  5. Prevent legal liability or respond to claims made against the Company.

5.2. Third-Party Obligations

We ensure that any third party receiving such data is legally bound to maintain confidentiality and process personal data in accordance with applicable privacy and data protection regulations.

6. TRANSFER OF YOUR INFORMATION

6.1. International Transfers

Given the international nature of our operations and service infrastructure, your personal data may be transferred to, stored, and processed in jurisdictions outside of your country of residence. These jurisdictions may not provide the same level of data protection as the laws in your home country.

6.2. Consent to Cross-Border Transfer

By agreeing to this Privacy Policy and submitting your personal data through the Stockity Website or Mobile Application, you acknowledge and explicitly consent to such cross-border transfers. Transfers are made only as necessary to execute the Stockity Client Agreement, fulfill our Services, or as permitted under applicable law.

6.3. Safeguards

We take all necessary measures to ensure that any transfer of your personal data outside your jurisdiction is conducted with adequate protection. Such measures may include:

• Entering into contractual agreements with recipients containing standard data protection clauses approved by regulatory authorities;
• Ensuring third-party service providers (including cloud storage providers and customer support systems) operate under a robust data protection framework;
• Requiring these third parties to maintain appropriate technical and organizational safeguards to protect your data from unauthorized access, use, or disclosure.

6.4. Limitation of Transfers

No transfer of your personal data will occur unless we are satisfied that adequate controls have been implemented to ensure the security, confidentiality, and lawful handling of your information in accordance with this Privacy Policy and applicable legislation.

7. YOUR RIGHTS REGARDING YOUR INFORMATION

7.1. Recognition of Your Rights

We acknowledge your rights under applicable data protection laws and are committed to assisting you in exercising these rights transparently and effectively. Subject to legal and contractual limitations, you have the following key rights regarding your personal data:

• Right of Access: You have the right to request confirmation of whether we are processing your personal data, and if so, to receive a copy of the personal data we hold about you, along with relevant information regarding its processing.

• Right to Rectification: You have the right to request correction or completion of inaccurate or incomplete personal data we hold about you. In certain cases, we may need to verify the accuracy of new information provided before making updates.

• Right to Erasure ("Right to be Forgotten"): You have the right to request the deletion of your personal data when there is no longer a lawful basis for us to continue processing it. This right may be exercised subject to specific provisions outlined in applicable laws.

• Right to Restrict or Object to Processing: You may request the restriction of processing of your personal data or object to certain types of processing (e.g., direct marketing or profiling based on legitimate interests) under specific circumstances.

• Right to Withdraw Consent: If we rely on your consent as a legal basis for processing your personal data, you have the right to withdraw that consent at any time. Please note that this does not affect the lawfulness of processing carried out before the withdrawal.

7.2. Limitations

These rights are not absolute and may be subject to limitations under applicable laws and regulations, particularly relating to anti-money laundering (AML), Know Your Customer (KYC) principles, financial reporting, or other legal obligations binding us. In some situations, exercising certain rights (such as the right to erase or restrict processing) may prevent us from continuing to provide services to you or may result in the termination of contractual relationships.

8. INFORMATION WE SHARE WITH THIRD PARTIES

8.1. General Rule

We do not disclose or transfer your personal data to any unaffiliated third parties except where disclosure is necessary to fulfill our contractual or legal obligations, provide our services to you, or pursue our legitimate interests in accordance with this Privacy Policy.

8.2. Third-Party Processing

Third parties receiving your personal data from us do so entirely on our behalf and only under our documented instructions. These third parties are contractually bound to maintain the confidentiality and security of your information and may include:

1. A limited number of our employees or employees of affiliated entities who require access to personal data to perform their duties;
2. Independent professional auditors for compliance or regulatory audit purposes;
3. Dispute resolution organizations or arbitrators handling claims or legal complaints from you;
4. Payment systems and financial institutions involved in processing your transactions;
5. Payment system providers assisting with deposits, withdrawals, and other monetary operations;
6. Identity verification and KYC service providers to comply with AML/CTF requirements;
7. Infrastructure and IT service providers whose technology is critical for the functionality and reliability of the Stockity Trading Platform.

8.3. Verification Services

For identity and transaction verification, we cooperate with Sum and Substance Limited (UK Registration No. 09688671). This provider receives personal data you submit during verification procedures. For more information, please see SumSub’s Privacy Policy: https://sumsub.com/privacy-notice/

8.4. Aggregated and Anonymous Data

We may also provide aggregate, anonymized, or statistical information to third-party analytics and marketing partners that do not directly identify you. This information includes:

• Google Analytics: Tool used to evaluate user interactions with the Stockity Trading Platform, helping improve performance and personalize advertising. More info: https://policies.google.com/privacy
• Cloudflare: Network and security platform processing and protecting your data during transmission and hosting. Data may be stored on servers located in the EU and the US. More info: https://www.cloudflare.com/privacypolicy/
• Zendesk: Support service provider processing communications with our support team. When you initiate contact, data you provide (such as name, email, and inquiries) may be accessed by Zendesk. More info: https://www.zendesk.com/company/agreements-and-terms/privacy-policy/

8.5. Promotional Fulfillment

For delivering promotional materials, rewards, or branded gifts (either in loyalty programs or one-time campaigns), we may share your full name, shipping address, and phone number with postal or courier services and our promotional partners solely for delivery purposes.

8.6. Business Transactions

In the event of a merger, acquisition, or restructuring, your personal data may be transferred to a new entity, provided that the receiving party commits to continue protecting your data according to this Privacy Policy.

8.7. International Transfers

We may transfer your personal data to countries outside the European Economic Area (EEA). When such transfers occur, we ensure that adequate safeguards (such as contractual clauses and technical measures) are implemented to guarantee a level of protection comparable to that provided within the EEA.

8.8. Exceptional Circumstances

In exceptional cases, and only with your explicit prior consent, we may share your personal data with third parties not listed in this Privacy Policy for clearly specified purposes explained at the time consent is requested.

9. PROTECTING TECHNICAL AND PERSONAL INFORMATION

9.1. Security Measures

We implement a comprehensive set of administrative, technical, and organizational safeguards designed to protect your personal data and all other information submitted or stored via the Stockity Trading Platform. These security practices aim to maintain data confidentiality, prevent unauthorized access, and ensure the integrity of our systems.

9.2. Data Transmission Security

To protect data transfers between your device and our servers, we use Secure Sockets Layer (SSL) encryption technology. This ensures that all communications, including login credentials, financial transactions, and personal data submission, are transmitted securely and encrypted, preventing interception or tampering by third parties.

9.3. Limitations of Security

While we apply industry-standard technologies and practices to safeguard your data, it is important to understand that no method of transmission over the internet or electronic storage is completely secure. Therefore, we encourage you to exercise caution when sharing sensitive information online and to use strong, unique passwords to secure your Account.

10. PASSWORDS AND ACCOUNT SECURITY

10.1. Account Creation

When creating an account on the Stockity Trading Platform, you are required to provide a valid email address and create a strong, confidential password to access your account. This password is known only to you and cannot be viewed or accessed by our system in plain text.

10.2. Responsibility

For your protection, we do not have the ability or right to change your password or email credentials. You are fully responsible for maintaining the confidentiality of your login credentials and for all activities conducted through your account.

10.3. Recommendations

We strongly recommend that you:

• Use a unique and complex password containing a mix of letters, numbers, and symbols;
• Avoid using the same password across multiple services;
• Change your password regularly and immediately if you suspect a security breach.

10.4. Reporting Suspicious Activity

If you detect or suspect unauthorized use of your account, or notice other suspicious activity (such as login attempts from unfamiliar locations or unexpected profile changes), you must promptly notify our Support Services. Timely reporting allows us to take swift action to secure your account and investigate potential breaches.

11. USE OF OUR SERVICES BY MINORS

11.1. Age Requirement

Our services, including access to the Website, Stockity Mobile Application, and related features of the Stockity Trading Platform, are intended only for individuals who have reached the age of majority under applicable laws in their respective jurisdictions. We do not knowingly collect, process, or store personal data from minors legally required to enter binding agreements or access financial platforms.

11.2. Handling Underage Data

If we become aware or have reason to believe that someone who does not meet the minimum legal age has attempted to register or provide personal data through our services, we will promptly take steps to remove such information from our systems and close the associated account.

11.3. Parental Responsibility

We strongly encourage parents and legal guardians to monitor the online activities of minors and assist us in enforcing this provision by promptly notifying our support services if they suspect unauthorized access or registration by a minor.

11.4. Representation and Warranty

By using the Stockity Trading Platform, you represent and warrant that you are of legal age according to your jurisdiction and have full legal capacity to use the services we provide.

12. CHANGES TO THIS PRIVACY POLICY

12.1. Right to Update

We reserve the right to revise, update, or modify this Privacy Policy from time to time to reflect changes in laws, regulations, our practices, or improvements to applicable services. Any changes we make will not limit or reduce your legal rights under applicable data protection laws.

12.2. Publication of Changes

Whenever we make material changes to this Privacy Policy, the revised version will be published on the Website and will indicate the last revision date. Unless stated otherwise, the new version will take effect immediately upon publication. We may also notify you via email or other reasonable communication methods regarding significant changes.

12.3. Continued Use

Your continued use of the Website, Stockity Mobile Application, or our Services after the revised Privacy Policy takes effect constitutes your acknowledgment and acceptance of the updated terms. If you do not accept the revised Privacy Policy, you must discontinue use of the Stockity Trading Platform and may close your account by withdrawing your funds and contacting our support services using the contact methods described in the Stockity Client Agreement.

12.4. Language Discrepancies

In the event of any discrepancy between the English version of this Privacy Policy and its translation into other languages, the English version shall prevail for purposes of interpretation and legal enforcement.

13. CONTACT INFORMATION

13.1. Data Protection Inquiries

If you have questions, concerns, or requests regarding the processing of your personal data, or if you wish to exercise your rights as described in this Privacy Policy, including withdrawing consent or verifying the data we hold about you, you may contact our designated Data Protection team at the following email address: dataprotection@stockity.com.

Effective Date: October 21, 2025