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Privacy and Personal Data Protection Policy

Last updated: January 2026

1. Introduction

OTG GROUP Ltd ("OTG GROUP", "the Company", "we", "us", "our") is committed to protecting the privacy and personal data of our Clients and website visitors. This Privacy and Personal Data Protection Policy ("Policy") explains how we collect, use, store, share, and protect your personal information. By using our services, accessing our website, or providing your personal information, you consent to the collection and processing of your data as described in this Policy.

2. Information We Collect

We collect the following categories of personal information: a) Identity Information: Full name, date of birth, nationality, government-issued identification numbers, and copies of identification documents. b) Contact Information: Email address, phone number, residential address, and mailing address. c) Financial Information: Bank account details, payment card information, source of funds, net worth, annual income, and employment information. d) Trading Information: Trading history, account balances, transaction records, and trading preferences. e) Technical Information: IP address, browser type, operating system, device identifiers, login data, and cookies. f) Communication Records: Records of correspondence and communications with our support team, including emails, live chat transcripts, and phone call recordings.

3. How We Use Your Information

We use your personal information for the following purposes: a) Account Management: To open and maintain your trading account, verify your identity, and process your transactions. b) Service Delivery: To provide our trading services, execute your orders, and manage your account. c) Regulatory Compliance: To comply with our legal and regulatory obligations, including AML/KYC requirements. d) Risk Management: To assess and manage the risks associated with providing our services. e) Communication: To send you important account notifications, service updates, and marketing communications (where you have opted in). f) Improvement: To analyse usage patterns and improve our products, services, and user experience. g) Security: To protect against fraud, unauthorised access, and other security threats.

4. Legal Basis for Processing

We process your personal data on the following legal bases: a) Contractual Necessity: Processing is necessary for the performance of our contract with you (Client Agreement). b) Legal Obligation: Processing is necessary to comply with legal or regulatory requirements. c) Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, risk management, and service improvement. d) Consent: Where we rely on your consent for specific processing activities (such as marketing communications), you have the right to withdraw your consent at any time.

5. Data Sharing and Disclosure

We may share your personal information with the following categories of recipients: a) Service Providers: Third-party service providers who assist us in delivering our services, including payment processors, IT service providers, and cloud hosting providers. b) Regulatory Authorities: Government agencies, regulators, and law enforcement bodies when required by law or regulation. c) Professional Advisors: Legal, accounting, and auditing firms engaged by the Company. d) Affiliated Companies: Other entities within the OTG GROUP of companies for operational and administrative purposes. e) Liquidity Providers: Our liquidity providers and counterparties as necessary for trade execution. We require all third-party recipients to respect the security of your personal data and to treat it in accordance with applicable data protection laws.

6. Data Retention

We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including: a) Active Accounts: For the duration of your business relationship with us. b) Closed Accounts: For a minimum period of five (5) years after the closure of your account, or longer if required by applicable law or regulation. c) Marketing Data: Until you withdraw your consent or opt out of marketing communications. After the applicable retention period, your personal data will be securely deleted or anonymised.

7. Your Rights

Subject to applicable law, you have the following rights regarding your personal data: a) Right of Access: The right to request a copy of the personal data we hold about you. b) Right to Rectification: The right to request correction of inaccurate or incomplete personal data. c) Right to Erasure: The right to request deletion of your personal data, subject to our legal and regulatory obligations. d) Right to Restriction: The right to request that we restrict the processing of your personal data. e) Right to Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format. f) Right to Object: The right to object to the processing of your personal data for certain purposes, including direct marketing. To exercise any of these rights, please contact us at privacy@otggroup.net.

8. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include: a) Encryption of data in transit and at rest using industry-standard protocols (SSL/TLS). b) Access controls and authentication mechanisms to restrict access to personal data. c) Regular security assessments and penetration testing. d) Employee training on data protection and information security. e) Incident response procedures for identifying and responding to data breaches. While we take all reasonable steps to protect your personal data, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security of your data.

9. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience and to collect information about how you use our website. Cookies are small text files stored on your device. We use the following types of cookies: a) Essential Cookies: Necessary for the operation of our website and services. b) Analytical Cookies: Help us understand how visitors interact with our website. c) Functional Cookies: Enable enhanced features and personalisation. d) Marketing Cookies: Used to deliver relevant advertisements and track marketing campaign effectiveness. You can manage your cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of our website. For any questions about this Privacy Policy, please contact us at privacy@otggroup.net.