Website Privacy Notice

1. Scope

This Privacy Notice applies only to the public Website and pre-customer communications described below. It is not intended to replace any financial privacy notice, customer privacy notice or service-provider privacy notice that may apply when an individual applies for or receives a financial product or service.

This Notice applies to Website visitors, prospective business customers, business representatives, prospective partners and other people who communicate with us through the public Website.

2. Who we are

Fiducia Clearing Limited is responsible for personal information processed under this Website Privacy Notice.

Fiducia Clearing Limited 30 N Gould St Ste R Sheridan, WY 82801 United States

Email: support@fiduciaclearing.com

3. Personal information we collect

Information you provide

Depending on how you interact with us, we may collect:

• full name;
• work or personal email address;
• telephone number;
• company or organization name;
• company website;
• job title or relationship to an organization;
• industry and business activity;
• anticipated monthly transaction volume;
• expected currencies, countries, payment corridors or settlement requirements;
• partnership or pricing requirements;
• application, inquiry and communication content;
• communication and consent preferences; and
• other information you voluntarily provide.

Do not submit passwords, authentication codes, private keys, seed phrases or sensitive identity documents through general Website forms or ordinary email.

Information collected automatically

When you use the Website, we and our hosting or security providers may process:

• IP address;
• browser and device information;
• operating system;
• access dates and times;
• requested pages and referring URLs;
• server, security and error logs; and
• cookie-consent preferences.

Information about other people

You may provide information about business owners, directors, employees, representatives or other connected individuals.

You are responsible for ensuring that you are authorized to provide this information and, where required, for making this Privacy Notice available to those individuals.

4. Sources of personal information

We may obtain personal information:

• directly from you;
• from an organization or representative with which you are connected;
• automatically through the Website and its infrastructure;
• from communications and email service providers;
• from public business records or publicly available sources; and
• from professional advisers, service providers or authorities where lawful and relevant.

5. How we use personal information

We may use personal information to:

• respond to inquiries and expressions of interest;
• evaluate prospective customer, partner and service relationships;
• understand anticipated account, payment, currency and settlement requirements;
• communicate about applications, onboarding, products, pricing or partnerships;
• verify information and prevent fraud, abuse or security incidents;
• operate, maintain and protect the Website and our systems;
• maintain business, compliance and communication records;
• comply with legal, regulatory, sanctions and law-enforcement obligations;
• establish, exercise or defend legal claims;
• improve Website functionality and user experience;
• send promotional communications where separately requested, consented to, or otherwise permitted by law; and
• evaluate or complete a merger, acquisition, financing, reorganization or sale.

6. Legal bases for processing

Where applicable data-protection law requires a legal basis, we process personal information based on one or more of the following:

• your consent;
• steps taken at your request before entering into a contract;
• performance of a contract;
• compliance with legal obligations;
• our legitimate interests in operating, securing and improving our Website and business; and
• establishing, exercising or defending legal claims.

Where processing is based on consent, you may withdraw consent at any time. Withdrawal does not affect processing completed before withdrawal.

7. How we disclose personal information

We may disclose personal information to:

• Website hosting, infrastructure and security providers;
• email delivery and communications providers;
• technical support and fraud-prevention providers;
• identity-verification and compliance providers if an onboarding process begins;
• banking, payment, liquidity, custody or other regulated service providers where relevant, authorized and legally permitted;
• professional advisers, including lawyers, accountants, auditors and insurers;
• regulators, courts, law-enforcement agencies and government authorities;
• parties involved in a proposed or completed merger, acquisition, financing, reorganization or sale; and
• other parties at your request or with your authorization.

Service providers are expected to process information for authorized purposes and subject to applicable contractual or legal obligations.

8. Sale, sharing and targeted advertising

We do not sell personal information or share personal information for cross-context behavioral advertising, as those terms are defined under applicable U.S. state privacy laws.

We do not currently use targeted-advertising technologies on the Website.

If our practices change, we will update this Privacy Notice and provide any notices, preference controls or opt-out mechanisms required by applicable law before engaging in such activities.

9. Cookies

The Website uses a necessary cookie to remember your cookie and privacy preferences. This cookie does not perform targeted advertising.

Optional analytics are currently disabled. Analytics technologies will not be activated unless appropriate disclosures and, where required, consent controls are in place.

You may review or change your preferences through the Cookie Settings control available on the Website. Browser settings may also allow you to block or delete cookies, although doing so may affect Website functionality.

10. Data retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Notice, including responding to requests, evaluating a prospective relationship, maintaining security and business records, complying with law, resolving disputes and enforcing agreements.

The exact retention period depends on the nature and status of the inquiry, our relationship with you, applicable legal and recordkeeping requirements, security and fraud-prevention needs, and whether information is needed to resolve a dispute or enforce an agreement.

If an applicant becomes a customer, personal information may be retained for longer periods under the applicable customer privacy notice, service-provider requirements and financial-crime, tax, accounting and recordkeeping laws.

Cookie-consent preferences are normally stored for up to 180 days before the Website asks you to confirm them again.

11. International transfers

Fiducia Clearing and its service providers may process personal information in the United States and other countries. Those countries may have privacy laws different from the laws where you live.

Where required by applicable law, we will use applicable safeguards for international transfers, which may include contractual protections or other approved transfer mechanisms.

12. Information security

We use reasonable administrative, technical and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration and disclosure.

No internet transmission or storage system can be guaranteed completely secure. You should not send confidential credentials or sensitive identity documents through ordinary email or general Website forms.

13. Your privacy rights

Depending on where you live and subject to applicable exceptions, you may have the right to:

• request access to personal information;
• request correction of inaccurate information;
• request deletion of information;
• request restriction of processing;
• object to certain processing;
• withdraw consent;
• request a portable copy of information;
• opt out of marketing communications;
• opt out of a sale or sharing of personal information, if those activities occur;
• appeal certain privacy-request decisions; and
• lodge a complaint with an appropriate privacy authority.

These rights may be limited by legal, regulatory, security and recordkeeping requirements.

Privacy requests may be sent to support@fiduciaclearing.com. We may request information reasonably necessary to verify your identity and authority. We will use verification information only for verification and related security purposes.

Where applicable, an authorized agent may submit a request on your behalf. We may require proof of the agent’s authority and direct verification from you.

We will not unlawfully discriminate against you for exercising an applicable privacy right.

14. California privacy disclosures

If California privacy law applies to our processing, California residents may have rights to know, access, correct and delete personal information and to opt out of its sale or sharing. They may also have the right to limit certain uses of sensitive personal information and to use an authorized agent.

During the preceding 12 months, we may have collected the categories of identifiers, professional or employment-related information, commercial or business-interest information, internet or electronic-network activity and correspondence described in this Notice. We use and disclose those categories for the purposes and to the recipients described above.

We have not sold personal information or shared personal information for cross-context behavioral advertising during the preceding 12 months. We do not knowingly sell or share personal information of individuals under 16.

15. Marketing communications

Public Website forms are currently used to respond to inquiries, applications, pricing requests and partnership requests, not to enroll you in unrelated promotional email. If we introduce promotional email, we will provide any consent, notice and unsubscribe mechanism required by applicable law. You may also contact us at support@fiduciaclearing.com.

A promotional opt-out will not prevent operational, application-related, legal, compliance or security communications.

16. Children

The Website is intended for adults and is not directed to children. You must be at least 18 years old to submit an application or expression of interest.

We do not knowingly collect personal information from children under 13. If you believe a child has provided personal information, contact us so that we can review and delete it where appropriate.

17. Third-party websites

The Website may contain links to third-party websites. Their privacy practices are governed by their own notices and policies. Fiducia Clearing is not responsible for third-party privacy practices solely because the Website contains a link or reference.

18. Changes to this Privacy Notice

We may update this Privacy Notice periodically. The updated version will be posted with a revised “Last Updated” date. Additional notice will be provided where required by law.

19. Contact and complaints

Privacy questions, requests and complaints may be sent to:

Fiducia Clearing Limited 30 N Gould St Ste R Sheridan, WY 82801 United States

Email: support@fiduciaclearing.com

We will review privacy complaints and respond within the period required by applicable law.