Privacy Policy

Introduction

We ask that you read this website privacy policy carefully as it contains important information on who we are, how and why we collect, store and use personal information when you visit our website and on how and why we share such personal information. It also explains your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation (EU) 2016/679 (commonly known as the "GDPR"), which applies across the European Union and we are responsible as the controller of that personal information for the purposes of that law.

Who we are

This website is operated by Ultimate Fintech Marketing Ltd (we, us, our or UF Agency). We are a limited liability company registered in the Republic of Cyprus with registration number HE435151. Our registered address and our head offices are both located at 11 Apostolou Andrea, Hyper Tower 3rd Floor, 4007 Limassol, Cyprus.

Our website

This privacy policy relates to your use of our website [ultwire.com]. Throughout our website we may link to other websites owned and operated by third parties. These other third party websites may also gather information about you in accordance with their own separate privacy polices. For privacy information relating to these other third party websites, please consult their privacy policies as appropriate.

Our collection and use of your personal information

We collect personal information about you when you access our website, you contact us by submitting any of the contact forms through our website or send us feedback.

We collect this personal information from you:

• directly, such as when you contact us or send us feedback;
• indirectly, such as through your browsing activity while on our website (see 'Cookies' below); and
• through third parties or publicly available sources, such as analytics providers

The personal information we collect about you depends on the particular activities carried out through our website. Such information includes:

• your name, address and contact details
• details of any communication you have with us or feedback you give us
• the name of your employer or company and your job title
• information about how you use our website (usage data)
• IP address, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website
• your preferences in receiving marketing from us and our third parties and your communication preferences

We use this personal information to:

• provide and maintain our website, including allowing you to participate in interactive features of our website when you chose to do so
• manage our relationship with you
• communicate with you
• provide customer care and support
• run, administer and protect our business
• customise our website and its content to your particular preferences
• notify you of any changes to our website or to our services that may affect you
• monitor the usage of our website and detect, prevent and address technical issues
• improve our website and services

This website is not intended for use by children under the age of 18 and we do not knowingly collect or use personal information relating to children.

The legal basis for processing your personal information

When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases upon which we may rely, depending on what personal information we process and why.

The legal bases we usually rely on include:

• consent: where you have given us clear consent for us to process your personal information for a specific purpose
• contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract
• legal obligation: where our use of your personal information is necessary for us to comply with the law
• legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests).

Further information—the personal information we collect, when and how we use it

For further details on when we collect personal information, what we collect as well as how we use it, please read the following table:

Marketing

We may use your personal information to send you (by email, text message, telephone or post) information about our services and those of other members of our group.

We rely on your consent to send you promotional and marketing communications and we will ask for this consent separately and clearly.

Where you have provided your consent for promotional and marketing communications, you have the right to withdraw it at any time by:

• emailing, calling or writing to us—see below: 'How to contact us'
• using the 'unsubscribe' link in email

We will always treat your personal information with the utmost respect and never share it for marketing purposes with other organisations outside our group.

For more information on your rights in relation to marketing, see 'Your rights' below.

Who we share your personal information with

We routinely share personal information with:

• companies within our group;
• other third parties we use to help us run our business, e.g. email automation platforms or website hosts. To receive a list of such third parties please contact us (see 'How to contact us' below);
• professional advisers including lawyers, consultants and auditors who provide legal, consultancy and auditing services to us; and
• our insurers and banks

Some of those third-party recipients may be based outside the European Economic Area — for further information including on how we safeguard your personal data when this occurs, see 'Transfer of your information out of the EEA'.

We only allow third parties to handle your personal information if we are satisfied, they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies, authorities and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. Usually, information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Where your personal information is held

Your personal information is usually held at our offices and those of our group companies. However, once shared, it may also be held with our service providers, representatives and agents as described above (see above: 'Who we share your personal information with').

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: 'Transfer of your information out of the EEA'.

How long your personal information will be kept

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

We will usually keep your personal information while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you in accordance with the law; and
• to keep records required by law. For example, we have to keep basic information about our financial transactions with our customers for six years after the year in which they take place for tax purposes.

Different retention periods apply for different types of personal information. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. When it is no longer necessary to retain your personal information, we will delete or anonymise it. Details of retention periods for different aspects of your personal data are set out in the table in 'Further information—the personal information we collect, when and how we use it' above.

Transfer of your information out of the EEA

It is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

• with our service providers located outside the EEA. To receive a list of such providers please contact us (see 'How to contact us' below);
• with other members of our group outside the EEA. To receive a list of such entities please contact us (see 'How to contact us' below); and
• if you are based outside the EEA.

These transfers are subject to special rules under European and Cyprus data protection law. Whenever we transfer your personal information out of the EEA, we ensure a degree of protection similar to that afforded in EEA countries is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission.
• Where we transfer your personal information to countries that have not been deemed to provide an adequate level of protection for personal information by the European Commission, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe.

If you would like further information please contact us (see 'How to contact us' below).

How to contact us

Address: Apostolou Andrea 11, 3rd Floor, Mesa Geitonia, 4007 Limassol, Cyprus.

Email: hello@ultwire.com

Phone: +357 25 028710