Our confidentiality agreement includes the provisions that we, as RAVEX LLC company, stipulate for the information and services we provide to our valued investors. We request you to review this contract in detail.

Your privacy is very important to us. We are committed to protecting and respecting your personal data. This Privacy Policy explains how/when we will use your personal data, how we will keep it secure and the types of personal data we collect about you when you choose to use our services. It also aims to help you protect your personal data and your rights.

It is important that you check this page for any updates, as we reserve the right to make changes to our privacy policy from time to time. The personal information we obtain is subject to our most current privacy statement. Since the changes made in this text are important, we would like to state that we can forward the update notifications to our investors. If you are an employee or third party service provider operating in the RAVEX LLC family; It will be ensured that your personal data, business policy and contractual bond are used in accordance with our other policies in the current position by communicating with our company.

In our aforementioned confidentiality agreement; “our”, “us”, “we” or “RAVEX LLC” sources are a reference to each group company within Georgia, Tbilisi, Chugureti District, Iv. Javakhishvili Street, N91, Residential Area, Floor 1, Apartment N2b

, which is the address of our group companies due to context potency, unless otherwise stated.

Likewise, “you”, “yours”, “yours” or “yours” resources in this privacy policy are a reference to the name of our potential investors, arising from the content potency, unless otherwise stated.

When you use any of our communication channels to contact us or when you enter our website; You agree that you have read and understood the terms of this statement and that you know how we process any personal data you share with us before you become an investor.

With this policy, you agree that you know how we obtain, store, process, share and manage your personal data/rights throughout our business relationship and after the termination of the customer relationship, including an update you will make after you create your account at RAVEX LLC.

ABOUT US

This privacy policy applies to the processing activities of data controller assets within the RAVEX LLC of companies at the following address:

RAVEX LLC

Georgia, Tbilisi, Chugureti District, Iv. Javakhishvili Street, N91, Residential Area, Floor 1, Apartment N2b

Collection and Storage of Personal Information

The personal information requested from our investors and potential investors serving within our company is as follows:

• Name, surname and contact information
• Date of birth and gender information.
• Information on income and wealth status, including details of assets and liabilities, account balances, transaction submissions, tax and financial statements.
• Occupation and employment details.
• Location data.
• Data and experience in trading risk tolerance and risk profile.
• Data for IP address, device characteristics and trading experience.
• Bank account, e-wallet and credit card information.
• your visits to the RAVEX LLC site or RAVEX LLC applications; Various details including traffic data, location data, blogs and other communication data.

COOKIES

We use cookies to collect and store information about your use of the RAVEX LLC site.

Cookies are small text files stored by the browser on your device’s hard drive and when you enter the RAVEX LLC site they send back data to our web server that needs to be reloaded.

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 in the “Our Cookies Policy” section on the RAVEX LLC site.

In addition, we keep records of your business activities, including:

• Products you trade with RAVEX LLC company
• Historical data on your investments
• The choices you make for a particular product or service

If you are opening a new account or signing up for an existing account, the law must provide for you. Anti-money laundering laws require that we view and record the details of certain documents (photographic and non-photographic documents) to meet the standards set under those laws.

Identity documents required under money laundering legislation or other legislation related to the services we provide to you include:

• Passport
• Driver’s license
• National identity document (if applicable)
• electricity bills
• Certificate of trust (if any)
• A credit check on the individual or
• Other data deemed necessary for our functions and activities.

If you are an institutional investor; You must share with us additional information such as company addresses, shareholders, directors, officers, including additional personal information about shareholders and directors.

We reserve the right to request additional information as deemed necessary to comply with our legal and requirements.

The said data; We obtain our services in a variety of ways using our websites, account sign-up apps, demo sign-up forms, webinar sign-up forms, website cookies, and similar tracking technologies built into our website and apps.

News changes and information provided during our updates; We also have the right to access data about our investors through third party marketing lists purchased from third parties, public sources, social media platforms, brokers and affiliates, bankers and credit card processors, subscription-based intelligence databases, and other third parties.

Other than these, we may request personal data at certain time intervals at our own request. (for example, through market research, surveys or special offers).

If you do not want to provide information that will enable us to fulfil your request for a particular product or service, we may not be able to provide you with the requested product or service.

We may record any communication we have, electronically or by telephone, regarding the services we provide to you and our relationship with you.

The aforementioned records will be the sole property of our company and will provide proof of communication between the company and the investor.

Such phone conversations can be recorded without a warning tone or other warning. In addition, please note that if you visit any of our offices or facilities, we may have CCTVs that will record your image.

WITH WHOM CAN YOUR PERSONAL DATA BE SHARED?

• As part of the use of your personal information for the purposes outlined above, we may disclose your information to:
• Companies that provide financial and other services within the RAVEX LLC.
• Third-party application providers, when using RAVEX LLC proprietary applications, communication systems and trading platforms used by third parties.
• Service providers and specialist consultants contracted to provide administrative, IT, analytics and online marketing optimization, financial, compliance, insurance, research or other services.
• Persons who provide promotional services to brokers and affiliated entities with whom we have a reciprocal relationship.
• Payment service providers and banks that process your transactions.
• Auditors, consultants or contractors who oversee any of our business purposes.
• Agreements with law enforcement agencies and government agencies that respond to other requests where required by law.
• Any third party for whom such disclosures are necessary to enforce or enforce our Terms of Service and other related agreements.
• Anyone authorised by you.

We endeavour to disclose to these third parties only the minimum personal data necessary to fulfil 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 providing 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.

You can check their pages to learn about the privacy practices and procedures of third parties.

WHEN AND HOW DO WE GET YOUR APPROVAL?

We may process your personal information on behalf of one or more legal proceedings in relation to the reasons and purposes determined by our company. The situations referred to as legal basis are as follows:

• Fulfilling contractual responsibilities towards the investor
• Comply with legal and requirements
• To follow our legitimate interests

If one of the laws consisting of these three items is to be neglected while using the personal information of our investors, the approval of the investor is required. This permission will be given by the investor freely and freely.

The investor has the right to withdraw his consent at any time by contacting the company through the RAVEX LLC contact information specified in this privacy policy.

MANAGEMENT OF PERSONAL DATA

As RAVEX LLC; We are committed to protecting personal data transmitted, stored or otherwise processed. We will implement and maintain appropriate technical and organisational measures to protect against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, and to ensure the level of security required to protect the personal data provided to us from access.

We have appointed a “Data Protection Officer” to ensure that the management of personal information complies with this privacy statement and applicable legislation. Outside of the RAVEX LLC, we undertake that those who accept the confidentiality of this information, handle or receive personal information will respect the right to privacy and comply with all relevant data protection laws and these privacy statements.

The data protection measures we implement are:

• Our employees who deal with personal information are trained on security measures that require them to use two-factor authentication along with a password when accessing investor information and our system. In these security measures, Chinese walls are enforced and our employees can only access personal data necessary for the task they are performing.
• Data encryption technologies are used during data transfer in internet transactions.
• Client access codes transferred between networks using firewalls, intrusion detection systems and virus scanning tools are used against unauthorised persons and viruses entering our system.
• When sending electronic data for outsourcing; A clean desk policy is enforced at all facilities that provide secure storage for physical records, institutionally maintained by us and all our relevant institutions, using private secure networks or encryption.
• Physical and electronic means such as access cards, cameras and guards are used to protect against unauthorized access.

RETENTION PERIOD OF PERSONAL INFORMATION

We maintain personal data in a combination of secure computer storage facilities and paper-based files and other records. When we determine that personal data is no longer necessary, we will remove details that would identify the investor or securely destroy records. In addition, it may be necessary for us to keep records for a significant period of time. For example, we are subject to investment services and money laundering laws that require us to keep copies and evidence of actions taken from our company regarding identity verification, sources of income, tracking transactions, telephone, chat. Email communications, orders and trade history; By addressing your complaints and records, we can demonstrate that we comply with codes of conduct throughout the business relationship. These records must be retained for five years after our relationship with you has ended. When you opt out of receiving marketing communications, we will keep your information on our suppression list because we know you do not want to receive these communications. INVESTOR RIGHTS

Although not valid in all circumstances, the rights of investors are as follows:

• Requesting access to personal data (commonly known as “Data subject access request”)
• Request the correction of the personal data we hold about you
• To request the deletion of personal data. However, we may not always comply with your deletion request due to certain legal reasons which will be communicated to you at your request.
• Within the scope of your fundamental rights and freedoms, you can notify us of situations where you feel uncomfortable or think that your personal data will be processed on grounds that we depend on for a legitimate interest (or that of a third party).
• You also have the right to object to where we process your personal data for direct marketing purposes. In some cases, we may demonstrate that we have legitimate grounds for processing your information that overrides your rights and freedoms.
• To request the restriction of the processing of your personal data.

This allows you to request that we suspend the processing of your personal data in the following scenarios:

– When you ask us to determine the accuracy of the data

– Where the use of the data is unlawful but you do not want us to delete it; you can decide where you should keep the data without the need for us to hold it, unless you need it to establish, exercise or defend legal claims.

– You object to our use of your data. However, we need to verify whether it overrides legal reasons to use it.

• To request the transfer of your personal data to you or a third party. We will provide you or a third party of your choice with your personal data in a structured, commonly used, machine-readable format.
• You should note that this right only applies to automated information (for example, not hard copies) that you have consented to be used for you or that we use to conclude a contract with you.
• Withdraw your consent at any time to process your personal information.

INVESTOR COMPLAINTS AND REQUESTS

We try to respond to all requests within 1 (one) month. If the investor’s request is complex or excessive, our response time may take longer than 1 (one) month. In this case, we inform our investor within 1 (one) month from the receipt of the request and keep it updated. We may charge a reasonable fee when a request is manifestly unfounded, excessive or repetitive, or when we receive a request to provide more copies of the same data. In this case, we will send the investor a fee request that they must accept before processing their claim. Alternatively, we may refuse to comply with the investor’s request in these circumstances.