TradeZero, Inc.

Privacy Policy
Effective as of January 2024
Introduction

Your privacy is important to TradeZero, Inc. (hereinafter “TradeZero”, “we”, or “us”). We want
you to understand how we may collect, use, share, and keep information about you and the
choices that are available to you. This Privacy Policy sets forth the principal types of information
we and our affiliates may collect about you, the purposes for which we use the information, the
circumstances in which we may share the information, and other important terms that apply when
you utilize our “Services” which are principally our websites (“Sites”), our account funding and/or
trading applications (“Applications”), and account administration we provide to our customers.

By using our Services, you agree to this Privacy Policy, as it may be amended from time to time
(see “Changes to this Privacy Policy” below).

Personal Information We Collect From You And How We Collect It

Below, we describe in more detail the categories of personal information we may collect from you.

• Personal Identifiers – Name, address, date of birth, gender, marital status, email address,
telephone number, identifiers we assign to you including account numbers, usernames,
account IDs, family information, professional and employment information, and publicly
available photographs.
• Government Identifiers –Tax identification number, national identification number, other
government issued identification number (i.e., driver’s license, passport, or alien registration),
and photographs associated with any government issued identification document.
• Legally Protected Classification Characteristics – Age, citizenship, nationality, association with
senior political officials and /or executives of government owned enterprises.
• Device and Online Identifiers and Related Information – Internet Protocol (“IP”) address, account
username/log-in, device information, device type, browser type and version, time zone
setting and location, operating system and other technology on the devices you use to access
our Services.
• Internet, Application, and Network Activity – Emails, activity on our Sites and Applications,
including browsing history, search history, clickstream/online website tracking information
and other data related to user activity.
• Location Data – IP geo-location from which you connect to the internet when using our Sites
and Applications.
• Financial Information – Account number(s) and other information regarding accounts at other
financial institutions, your authority over, beneficial interest in and other information about
entities you are associated with; public company affiliations, bank and brokerage account
balance information, source of wealth information, investment goals and experience, net
worth and liquidity, income; tax classification, and other information regarding your financial
circumstances.

1
 • Entity Affiliations and Associations – Information regarding whether you or an immediate
family member are affiliated or associated with certain financial institutions including but not
limited to broker dealers, investment advisors, securities firms, securities exchanges, banks,
insurance, or trust companies.
• Audio Data – Recordings of telephone or similar calls.
• Transaction Information – When you receive, submit, or complete a transaction utilizing the
Services, we collect information about the transaction, such as, for example, transaction
amount, type, time, and date.
We may obtain information about you during direct interactions with us. You may provide us with
your personal information (including personal identifiers, financial information, government
identifiers, and professional or employment data) by filling in forms such as our account application,
by contacting us regarding our Services and Applications, or by responding to our marketing
activities. We may also obtain information about you through our affiliates, vendors, and other third
parties.
We may also obtain personal information about you from publicly available sources and from
companies that we do business with, such as consumer and investigative reporting agencies we use
to conduct background checks, verify your identity, creditworthiness, and Know Your Customer
(“KYC”) requirements. Furthermore, your interactions with third parties linked to our Services,
including but not limited to, TradeZero America Inc., TZ Clear LLC, Vision Financial Markets LLC,
various banks and their respective affiliates, your interactions with our social media sites, ad
campaigns, and other information from publicly available sources, such as public websites, may also
provide us with personal information. Please be aware that third-party websites and social media
sites are governed by their own privacy policies separate from our own.

Why We Collect And How We Use Your Personal Information

We collect and use your personal information for several important reasons. We use your personal
information to provide and optimize our Services for you, which includes, for example,
administering your account, communicating with you about your account, processing funding and
trading transactions for your account, troubleshooting issues with our Services, resolving technical
issues, and managing our relationship with you. We also use this information to comply with certain
anti-money laundering laws, regulations and KYC requirements including, without limitation, those
enforced by the Securities Commission of the Bahamas, the Financial Intelligence Unit of the
Bahamas, the Supreme Court of the Bahamas, and other applicable domestic and international
authorities. Furthermore, we use such information to help us safeguard your identity and your assets
as well as to help us prevent financial crime. Additionally, we may use your personal information, to
the extent permitted by applicable law, to conduct marketing activities that help us obtain and assess
data to improve and develop our Services and our relationship with you.

Who We Share Your Personal Information With

We Share Your Personal Information With The Following Third Parties:

• Your authorized agents and representatives or others to whom you instruct or authorize us

2
 to disclose your information and data;
• TradeZero’s lawyers, auditors, accountants and others who provide advice to TradeZero;
• TradeZero’s global affiliates who may help TradeZero provide Services to you by, for
example, engaging in customer support, transaction processing, operational and regulatory
functions;
• Non-affiliated companies that may assist us with, for example, transaction processing,
conducting research and development, or providing custodial services;
• Vendors who assist TradeZero with fulfilling its legal and regulatory obligations;
• Regulators and law enforcement authorities as required or permitted by law or regulation;
• Any person or entity to whom TradeZero is obliged by applicable law or regulation to
disclose your data; and
• Any other party where we have first obtained your prior consent.

We May Provide Your Information To Third Parties, Including Marketing Companies, For The
Purpose Of:
• Providing Services to you, according to the policies described with this Privacy Policy;
• Sending you marketing communications that we believe may be of interest to you;
• Improving Site and Application performance and personalizing your experience with
our Services, including presenting content, products, and services tailored to you;
• Performing analytics concerning your use of our Services including your responses to our
e- mails and the pages and advertisements you view while using the Sites or Applications;
and
• Any other purpose that we disclose at the time you provide, or when we collect,
your information.

Other Situations In Which Sharing Personal Information May Occur, Include:

• We may transfer personal information to a third party in the event of a merger,
divestiture, restructuring, reorganization, dissolution, or other sale or transfer of any or
all of our business, assets, or equity, and during negotiations for the same.
• We may aggregate your personal information in a manner that no longer reveals your
specific identity. We may use and disclose aggregated information for any purpose.
• We may also use and disclose, for any purpose, information that does not reveal your
specific identity or directly relate to you as an identifiable individual, including the
information described under “Information Collected Automatically,” below. If, however,
we are required to treat such information as personal information under applicable law,
then we may use and disclose it for the purposes for which we use and disclose personal
information, as detailed in this Privacy Policy.

Access And Choice

We may offer features through the Services that enable you to correct, update, or amend your
personal information. You may also e-mail customer support (see the “Contact Us” section
below), and we will comply with such a request to the extent required by law. Please note that we
may need to retain certain information for recordkeeping purposes and/or to complete any
transactions that you began prior to requesting a change or deletion. There may also be residual
information that will remain within our databases and other records, which will not be removed.

3
If you decide at any time that you no longer wish to receive marketing e-mails from us, please
follow the “unsubscribe” instructions provided in such e-mails. Please note that you cannot opt
out of administrative e-mails, such as regulatory, billing or service notifications.

Information Collected Automatically

When you utilize our Services, we record information such as browsing activity and data
displayed or clicked on (such as user interface elements, ads, and links) by using such tools as
Google Analytics, for example. Such tools also help us collect other information such as the
type of device you use, browser type, operating system version, IP address and date and time of
access. Similarly, we use tools and third parties, such as Segment and Customer.io to collect
your email information to track when and how you engage with our Services.

We may use certain technologies, such as cookies, web beacons, pixels, webhooks, and similar
technologies, to collect information automatically when you use our Services. We may use these
technologies to, for example, record your preferences, track your use of our Services across
multiple devices, measure exposure to our online advertisements, monitor traffic, analyze your use
of our Services, for security purposes, to display information more effectively, to personalize your
experience and to improve our Services.

You have choices to limit some tracking mechanisms. Many web browsers automatically accept
cookies, but you may be able to modify your browser’s settings to decline cookies. If you choose
to decline cookies, certain features may not function properly or may not remain accessible to you.
In addition, you may also render some web beacons unusable by rejecting or removing their
associated cookies.

We may also use information collected automatically from a particular browser, device, or
application to recognize you on another browser, device, or application linked to you, for fraud
prevention and other purposes.

• Log File Information - Certain information is collected by most browsers or automatically

through your device, such as your computer type, screen resolution, operating system name
and version, device manufacturer and model, language and Internet browser type and
version. We use this information to ensure that our Services function properly.

• IP Address - Your IP address is automatically assigned to your computer by your Internet

Service Provider. An IP address may be identified and logged automatically in our server log
files whenever a user accesses our Sites and Services, along with the time of the visit and the
pages visited. We use IP addresses for purposes such as calculating usage levels, diagnosing
server problems and administering our Services. We may also derive your approximate
location from your IP address.

• Cookies - Cookies are small text files that may be placed on your device when you use our
Sites and Services or when you view advertisements that we have placed on other websites.

4
 Cookies allow your browser to remember some specific information, which the web server
can later retrieve and use. When you quit your browser, some cookies are stored in your
computer’s memory, while some expire or disappear.

• Tags, Pixels, Web Beacons, Clear GIFs - A web beacon, also known as an internet tag, pixel tag,
or clear GIF, is typically a one-pixel, transparent image located on a webpage or in an e-mail.
These may be used when you are served with advertisements, when you interact with
advertisements outside of our online services, or when you interact with our
communications. They are generally used to transmit information back to a web server, and
they help us measure the success of our marketing campaigns and compile statistics about
usage of the Sites.

Do Not Track Signals

Currently, we do not respond to browser do-not-track signals or similar mechanisms. Please see the
“Information Collected Automatically” section above of this Privacy Policy for information on how
we use Cookies.

Security

We seek to limit access to your personal information to authorized employees, agents, contractors or
vendors. We also maintain physical, electronic, and procedural safeguards designed to protect the
information against loss, misuse, damage, or modification, and unauthorized access or disclosure
while in our possession. No data transmission or storage system can, however, be guaranteed to be
fully secure. If you have reason to believe that your interaction with us is no longer secure, please
immediately notify us in accordance with the “Contact Us” section below.

Other Important Information

• Consent to Use Your Information - The Services are controlled and operated by us from the
Commonwealth of the Bahamas and are not intended to subject us to the laws or
jurisdiction of any state, country, or territory other than that of the Commonwealth of the
Bahamas. You must be an individual of at least eighteen (18) years of age to use the Services.
If you use the Services outside of the Commonwealth of the Bahamas, you understand and
consent to the transfer of your personal information to, and the collection, processing, and
storage of your personal information in, the Commonwealth of the Bahamas and elsewhere.
The laws in the Commonwealth of the Bahamas and these countries regarding personal
information may be different from the laws of your country.

• Social Media and Links to Other Web Sites and Apps - This Privacy Policy applies only to our
Services. However, the Sites and Applications may contain links to other websites and apps
that are not operated or controlled by TradeZero and for which we are not responsible. You
should review the privacy policies of third-party websites and apps before using them.

• Use of Email - We keep our costs, and your costs, down by using email to communicate with

5
 you. For example, we may use email to notify you regarding your trading activity, of activity
in your account, or of new features, products or services that may affect the way you may be
able to use our Services.

Messages sent to us through the Contact Us pages on our Sites are secured with the same
technology we use for account information. We cannot guarantee the security of messages
you send directly to us addressed to our various email domains.

• To Whom This Privacy Policy Applies - This Privacy Policy applies to all Services provided by
TradeZero to its customers. However, if you have never been, or are no longer, a
TradeZero customer, the terms of this Privacy Policy may apply to you where applicable to
your jurisdiction.

• Access to Your Information - If you wish to review your personal information that we have on
file, please contact us (see the “Contact Us” section below). We will review any
information that you notify us is incorrect. If we agree, we will correct our records.
However, if we do not agree, you may submit a statement of dispute, which we will
include in future disclosures of the disputed information. WE SHALL NOT MAKE
AVAILABLE TO YOU, ANY INFORMATION COLLECTED IN CONNECTION
WITH, OR IN ANTICIPATION OF, ANY CLAIM, ARBITRATION, OR LEGAL
PROCEEDING UNLESS WE DETERMINE TO DO SO IN OUR SOLE
DISCRETION.

Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices or legal
requirements. The effective date at the top of this Privacy Policy indicates when this Privacy Policy
was last revised. Any changes will become effective when we post the revised Privacy Policy
through our Services. Your use of our Services following these changes means that you accept the
revised Privacy Policy. To stay informed of our privacy practices, we recommend you review the
Privacy Policy on a regular basis.

Contact Us

If you have any questions about our Privacy Policy, please contact us at support@tradezero.co.