1.1. nomo is a comprehensive digital trading platform managed by Nomo Trade Limited, a company registered as an International Business Company (IBC) in Saint Lucia under company number 2023-00509, with its registered office at Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, LC01 401, Saint Lucia (hereinafter “we,” “our,” “us,” or “nomo”).

1.2. nomo operates through both a website, available at https://nomotrade.com, and a mobile application (hereinafter “Platform” or “nomo”). This Platform allows users to engage in trading activities, including Contracts for Difference (CFDs) on various securities, derivative instruments, copy trading, and investment in diversified portfolios (hereinafter “Services”) a complete list and descriptions of our Services are available in the Terms and Conditions, which we encourage you to review.

1.3. The Platform is designed to operate in accordance with applicable legal and regulatory requirements, ensuring that all interactions are handled in compliance with applicable local and international laws.

1.4. This Privacy Policy (“Policy”) outlines how and why nomo collects, stores, processes, uses, shares, transfers, and retains your personal data when you interact with our Services whether through our website, mobile application, or any other online products or services we offer. It also applies when you communicate with us or receive communications from us in any form.

1.5. By using our Services or visiting our Platform, you consent to the collection, processing, and sharing of your personal data as described in this Policy.

1.6. We may periodically update this Policy, and the most recent version, available on our Platform, will govern the processing of your personal data. We encourage you to review this Policy regularly. In the event of material changes, we will notify you via email. Where required, we will also seek your consent or provide an opt-out opportunity for any new uses of your personal information. By continuing to use our Services after any updates, you acknowledge that you have reviewed the updated Policy and consent to the processing of your personal data as outlined.

1.7. At nomo, we are committed to ensuring the privacy and security of our users' data. We collect and process personal information that is necessary for legitimate business purposes, ensuring transparency by notifying users at the time of collection. We retain your personal data only for the duration required to fulfill the purposes for which it was collected, unless a longer retention period is required for legal compliance or to defend against legal claims.

1.8. Please review this Policy together with any other policies and documents published on the Platform so that you are fully informed about how and why we use your personal data.

2.1. nomo, as the entity responsible for processing your personal data, is dedicated to collecting, processing, and safeguarding your personal data when you interact with our Platform. This Policy aims to inform you about how and why we collect, use, and protect your data while you access and use our Services.

2.2. We respect your privacy and are fully committed to ensuring that your personal data is handled with the highest standards of security and confidentiality. nomo takes full responsibility for the collection and processing of your data, and we make every effort to protect your information from unauthorized access, loss, or misuse.

2.3. The primary objectives of this Policy are:

• to ensure that you are fully informed about the types of personal data we collect, the methods we use to process it, and the specific purposes for which it is used
• to fulfill our obligations under applicable laws, including anti-money laundering (“AML”) and know-your-customer (“KYC”) regulations, and to ensure that our Platform remains secure and in compliance with international standards
• to enhance your experience on nomo by providing personalized services, including tailored content, trading tools, and notifications relevant to your activities and preferences
• to implement necessary technical and organizational measures to protect your personal data against potential risks, including unauthorized access, alteration, or disclosure.

2.4. Through this Policy, we aim to provide clear information on how your personal data is handled by nomo, helping you make informed decisions regarding your privacy.

3.1. For the purposes of this Policy, the following terms have the meanings set forth below:
“Cookies” small text files placed on your device to enhance your browsing experience, used to store preferences, track activities, and analyze site traffic.
“Personal data” any information relating to an identified or identifiable individual, including but not limited to name, email address, phone number, financial data, and other information that can be used to identify or contact you.
“Sensitive data” any personal data that, due to its nature, requires a higher level of protection. This includes but is not limited to racial or ethnic origin, political opinions, religious or philosophical beliefs, health information, biometric data, sexual orientation, genetic data, and other information classified as sensitive under applicable data protection laws.

3.2. All other definitions, particularly those concerning our specific services and activities, can be found in the Terms and Conditions and other documentation available on our Platform.

4.1. This Policy applies to all users who interact with or visit the Platform, including both registered users and non-registered visitors:

• Visitors individuals who browse the Platform without creating an account. We still collect certain data to improve browsing experience and maintain Platform functionality.
• Registered users individuals who have created an account and actively use our Services. For these users, we collect additional personal data necessary to provide our Services, such as personal information, financial details, and transaction history.

In both cases, nomo ensures that your personal data is processed in accordance with this Policy and applicable data protection laws.

5.1. We collect the following categories of personal data depending on your interaction with our Platform:

• Identity data: full name; username or comparable identifier; marital status; title; nationality; date and location of birth; tax number; gender; information from identity documents, including biometric details such as facial images.
• Contact data: billing address; residential address; email address; telephone number.
• Screening data: close associations; political background; information linked to sanctions and adverse media.
• Risk assessment data: client risk score; client risk categorization.
• Economic and appropriateness data: employment status; annual income; source of income; current wealth value; annual investment plans; investment objectives; trading experience; level of education.
• Financial data: bank account details; payment card details.
• Transaction data: information regarding transactions, including payment details, withdrawals, exchanges, trading history, profits, account balance, deposit and withdrawal methods, and other relevant information.
• Technical data: IP address; login data; browser type and version; time zone and location; operating system and platform; other technology on devices used to access the Services; technical data from analytics providers such as Google, advertising networks, and search information providers.
• Communication data: details regarding payments to and from you concerning our Services.
• Profile data: username and password; interests; preferences; feedback; survey responses.
• Usage data: information on how you access and use our Services, including user sessions and, in certain instances, screen recordings.

5.2. Personal data may be classified as follows:

5.2.1. Based on how data is collected

• Directly collected data provided by you through interactions on our Platform, such as account creation, transactions, or support requests.
• Automatically collected data collected through your interaction with our Platform or device, such as IP addresses, device information, and browsing history tracked via cookies.

5.2.2. Based on the source of data

• First-party data collected directly from you through your interaction with the Platform.
• Third-party data received from external sources such as payment processors, identity verification services, or other third-party platforms used for marketing or service improvement, including data from regulatory bodies for compliance purposes.

5.3. We may also collect aggregated data that does not directly or indirectly reveal your identity. However, if we combine aggregated data with other data in a way that could identify you, we will treat that combined data as personal data and process it in accordance with this Policy.

6.1. nomo collects personal data through various methods and sources to ensure the seamless operation of our Services, enhance the user experience, and comply with legal obligations.

6.2. We collect personal data directly from you in the following interactions:

• when you register for an account, update your profile, complete verification, or change account settings
• when you contact us via email or through our customer support services
• when you subscribe to newsletters, promotional offers, or service updates
• when you complete forms or surveys provided by nomo
• if you participate in any contests, promotions, or marketing activities offered by nomo.

6.3. We may also collect personal data automatically through your interactions with our Platform, including:

• data about your activities on the Platform, such as pages visited, features used, and actions taken
• technical data about the devices you use to access our Services, such as device type, operating system, browser type, IP address, and unique device identifiers
• information about your approximate geographical location, derived from your IP address or device location services
• server logs containing IP addresses, timestamps, browser type, and other technical details related to your access to and use of the Platform.

6.4. We may also receive personal data from external sources, including:

• social media channels such as Facebook, Instagram, and LinkedIn, where you engage with us publicly
• search engines and analytics providers
• publicly available data from company registries for identity verification purposes
• financial institutions and payment processors providing transaction data for verification and fraud prevention
• third-party identity verification services conducting KYC checks
• advertising partners tracking user engagement and marketing effectiveness.

7.1. nomo processes your personal data for the following legitimate and necessary purposes:

• to deliver the core services of the Platform
• to personalize your experience by tailoring content, recommendations, and services based on your usage and trading activities
• to comply with applicable regulations, including AML and KYC requirements, and other legal obligations that help prevent fraud and ensure transaction security
• to conduct identity verification processes and perform necessary compliance checks
• to process your transactions, including deposits, withdrawals, and trade executions, and manage your account
• to provide transaction history, reports, and updates on your account status
• to monitor and detect unauthorized access or fraudulent activity and ensure the security of your account and personal information
• to protect against data breaches, cybersecurity threats, and other risks to Platform integrity
• to communicate important account-related information, including updates, system maintenance, or service changes
• to respond to your queries and provide customer support
• with your consent, to send promotional offers, newsletters, or marketing communications about products or services we believe may interest you
• to analyze your preferences and behavior to offer more relevant marketing content
• to fulfill our contractual obligations with you
• to resolve disputes or claims and for the defense of legal rights.

7.2. By collecting and processing your personal data for these purposes, we ensure that nomo can provide a secure, compliant, and user-friendly experience while adhering to applicable data protection laws.

8.1. nomo processes your personal data on the following grounds:

8.1.1. Your consent. In certain cases, we ask for your explicit consent to process your personal data, for example for marketing communications and newsletter subscriptions. You may withdraw your consent at any time by contacting us (see Section 19) or by using the opt-out options provided.

8.1.2. Contractual necessity. We process your personal data when necessary to perform our agreement with you or to take steps at your request prior to entering into an agreement. This includes providing access to our Services, processing trades, managing your account, and executing financial transactions.

8.1.3. Legal obligation. We process your personal data to comply with applicable legal and regulatory requirements, including KYC and AML obligations, record-keeping duties, and other regulatory requirements.

8.1.4. Legitimate business interests. We may process your personal data where it is in our legitimate business interests, provided those interests are not overridden by your privacy rights. This includes enhancing Platform security, preventing fraud, improving our Services, and analyzing Platform usage to offer a more personalized experience.

8.1.5. Protection of vital interests. In rare situations, we may process your personal data to protect your vital interests or those of another person, for example in an emergency situation where data is required to protect life or prevent harm.

8.2. We may also process sensitive categories of data, such as financial information and identification documents, when necessary to comply with legal or regulatory requirements including KYC and AML purposes. We will only process sensitive data based on your explicit consent or in accordance with legal obligations.

8.3. The table below outlines how we use your personal data, specifying the grounds we rely on for each purpose. Depending on the specific purpose, we may process your data on more than one ground.

8.4. Failure to provide necessary personal information may result in an inability to access or use our Services. Certain personal data is essential for us to offer our Services and ensure compliance with applicable legal obligations. Where such data is not provided, we may suspend or limit your access to our Platform until the necessary information is obtained and verified.

9.1. In certain circumstances, we may share or disclose your personal data in accordance with this Policy:

• with other companies within the Nomo Trade Limited group for operational purposes, including providing, maintaining, and improving our Services
• with third-party providers whose services or products are integrated with our Platform, such as communication systems and trading platforms. These providers are obligated to comply with privacy standards and may only use your personal data as necessary to provide their services to us
• with contracted service providers and advisers who assist in business operations, including IT services, analytics, marketing, and financial, regulatory, and compliance consultants, who are restricted from using your personal data for any other purposes
• with introducing brokers and affiliates who have mutual relationships with us
• with payment service providers and banks to process deposits, withdrawals, and other financial transactions
• with auditors and contractors who assist in auditing our operations or providing business advice
• with legal and regulatory authorities, courts, government bodies, and law enforcement agencies when required by law or authorized by legal agreements
• with third parties when necessary to enforce our terms and conditions
• with any entity authorized by you for specific purposes.

9.2. nomo ensures that any third parties with whom we share your personal data are required to handle it with care and in compliance with applicable data protection laws. They are bound by contractual obligations to use the data only for the specified purposes, ensure its security, maintain confidentiality, and prevent unauthorized disclosure.

9.3. Our Platform may contain links to third-party websites not covered by this Policy. We recommend that you review the privacy policies of any third-party websites you visit.

10.1. As part of our global operations, your personal data may be transferred to, stored, or processed in countries other than your country of residence. Where such transfers occur, we take appropriate steps to ensure that your data remains protected and that the transfer complies with applicable laws.

10.2. To ensure compliance for cross-border data transfers, we employ appropriate contractual safeguards and other measures as required by applicable law. You may request details of these arrangements by contacting us through the details provided in Section 19 of this Policy.

10.3. By using our Platform and Services, you acknowledge and consent to the transfer of your personal data to other jurisdictions as described in this Policy.

11.1. nomo retains your personal data only for as long as necessary to fulfill the specific purposes for which it was collected, in accordance with applicable laws and regulations. Retention periods may vary depending on the nature of the data and applicable regulatory requirements.

11.2. We observe retention practices in accordance with applicable laws and regulations in the jurisdictions in which we operate. Where authorities require us to retain personal data for longer periods, for example in connection with ongoing investigations or legal proceedings, we will comply with any lawful instructions issued by the relevant authorities.

11.3. When data is no longer necessary for business or legal purposes, we will either anonymize it or securely delete the records to prevent unauthorized access or use.

11.4. If you have not actively used our financial services for an extended period, we will securely delete or anonymize any personal data that can identify you, unless we can substantiate a legitimate reason for retaining the data for a longer period, as required by applicable law.

11.5. If an account application is incomplete or rejected, we will retain the data for the period required by applicable regulatory requirements.

11.6. At the expiration of the data retention period, we ensure that your personal data is irrevocably erased by secure destruction methods. We will also notify any third parties to whom your data was transferred and request that they implement similar actions.

12.1. As a user, you have several rights under applicable data protection laws regarding the personal data we collect, process, and store. While these rights may not apply in all situations, you are entitled to request the following:

• Access request. You have the right to request confirmation of whether your personal data is being processed by us, and to obtain a copy of that data.
• Correction request. If the personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it.
• Erasure request. You have the right to request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected, or when you withdraw consent. This right may be subject to limitations where data is required for legal obligations or ongoing legal claims.
• Objection to processing. You have the right to object to processing of your personal data where processing is based on our legitimate business interests. If you object, we will no longer process it unless we can demonstrate compelling grounds that override your rights, or the data is required for the establishment, exercise, or defense of legal claims.
• Processing restriction request. You may request a restriction on the processing of your personal data in specific circumstances, such as if you believe the data is inaccurate or if you object to processing while we verify the grounds for doing so.
• Data transfer request. You have the right to request the transfer of your personal data to you or to a third party in a structured, commonly used, and machine-readable format, where technically feasible.
• Opting out of marketing communications. You can configure your marketing preferences during account creation or via profile settings by clicking the opt-out link in any marketing email you receive or by emailing us at support@nomotrade.com.
• Right to withdraw consent. Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal will not affect the lawfulness of any processing that took place prior to withdrawal.
• Right to lodge a complaint. If you are dissatisfied with how we handle your data, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction. We encourage you to contact us first so that we can address your concerns.

12.2. To exercise any of your rights, please submit your request via email to support@nomotrade.com using the registered email address associated with your account. We may request additional information to verify your identity.

12.3. We aim to respond to data requests within 7 business days. If your request is complex or involves multiple requests, we will notify you of any delay and keep you updated.

12.4. While we aim to handle all requests free of charge, we may charge a reasonable administrative fee for requests that are manifestly unfounded, excessive, or repetitive.

13.1. nomo uses different types of cookies to improve your experience on our Platform.

13.2. For a detailed understanding of how we use cookies, how long we retain them, and how you can manage or block them, please refer to our Cookie Policy. The Cookie Policy provides comprehensive information about the various purposes for which cookies are used, how to manage browser settings, and details on cookies set by third-party service providers.

14.1. Our Services are not intended for individuals under the age of 18, and we do not knowingly collect or process personal data from children. By using our Platform, you confirm that you meet this age requirement.

14.2. If we become aware that we have inadvertently collected personal data from a child, we will take immediate steps to delete that data. If you believe we have collected data from a child, please contact us at support@nomotrade.com and we will promptly take the necessary actions.

15.1. The security and confidentiality of your personal data are of the utmost importance to us. We have implemented robust security measures to prevent unauthorized access, loss, misuse, alteration, or disclosure of your personal information, following industry best practices and applicable data protection requirements.

15.2. We employ strict access control measures to ensure that personal data is only accessible to employees, agents, contractors, and third parties with a legitimate business need to know. These individuals are required to process your data in accordance with our instructions and are bound by strict confidentiality obligations.

15.3. We use encryption technologies to ensure the secure transmission of your personal data during transit from your device to our servers.

15.4. All data related to your personal information is processed and stored in secure, dedicated data centers protected by state-of-the-art security measures, with network access strictly isolated from the internet.

15.5. Our infrastructure is continuously monitored and all events are analyzed in real time to detect vulnerabilities, malware, or unauthorized access attempts. In the event of a data accessibility issue, we have established data backup and recovery procedures to restore data quickly and minimize disruption.

15.6. Employees who handle your data are regularly trained on data security practices and confidentiality requirements. Access is strictly limited based on role and responsibilities, and all employee actions involving personal data are monitored.

15.7. When you register with nomo, you will be asked to choose a username and password. You are solely responsible for the security and usage of your account and must not share your login credentials with third parties. If you suspect unauthorized access to your account, please notify us immediately at support@nomotrade.com.

15.8. In the course of our business relationship, we generally do not engage in automated decision-making. However, in some cases we may use profiling to evaluate certain personal aspects, such as your trading behavior or risk profile, for the purpose of providing more tailored services. Where we use automated decision-making or profiling, we will inform you and seek your consent where required.

15.9. nomo retains your personal data for as long as necessary to provide Services, comply with legal obligations, and protect our legitimate interests. When data is no longer needed for these purposes, it will be securely deleted or anonymized.

16.1. nomo will not initiate contact with any individual who has not explicitly accepted our Terms and Conditions. This includes, but is not limited to, unsolicited advertising via email, phone, text message, social media, or other digital or physical channels.

16.2. nomo recognizes and respects the right of individuals to privacy and strictly adheres to all applicable anti-spam laws and regulations. All marketing communications will clearly disclose nomo’s identity, and we will never use spam or deceptive techniques in our marketing materials.

17.1. Security breach notification. In the unlikely event of a security breach, nomo is committed to notifying affected parties as promptly as possible. We will take immediate action to inform users of any significant security incidents and may post an official notice on our Platform. The notification will include details of the breach, potential consequences, and measures being taken to mitigate further risks.

17.2. Business changes and data transfer. In the event of significant business changes such as a merger, acquisition, or change of control, nomo reserves the right to transfer user information as part of the transition process. Users will be informed in advance of any such data transfers. In situations of bankruptcy or liquidation, appropriate safeguards will be in place to protect user data throughout such transitions.

18.1. nomo reserves the right to update or modify this Policy periodically in response to changes in regulations, our Services, or business practices. When we make updates, we will revise the effective date at the top of this Policy.

18.2. We will notify you of any material changes via email or other appropriate communication methods and may post a notice on our Platform. Please review this Policy periodically to stay informed about how we protect your personal data.

nomo is responsible for the collection, processing, and storage of your personal data as outlined in this Policy. For any questions, concerns, or requests regarding the processing of your personal data, or to exercise your rights under applicable data protection laws, please contact us:

• Email: support@nomotrade.com
• Operational address: Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, LC01 401, Saint Lucia.

We are committed to addressing your queries and ensuring that your rights are respected.