SOFTIC Website Data & Privacy Policy

1. Overview

All personal information processed by SOFTIC under this Data Protection & Privacy Policy (the "Privacy Policy") is controlled by SOFTIC Limited, a company registered in Hungary, with a formation number 01-09-731477, address: 1093 Budapest, Károly utca 131., Hungary (“SOFTIC”).

By "personal information" we mean all information that relates to, identifies or may identify you. We refer to ourselves in this Privacy Policy as "SOFTIC" or "we" and "our" and "us" shall be construed accordingly.

2. Purpose

We are committed to protecting and respecting your privacy. We collect, store and use information in accordance with the General Data Protection Regulations (EU) 2016/679 (the "GDPR") and any other relevant legislation and regulations as amended from time to time. For the purposes of the GDPR, we are the data controller of any personal data we collect, hold or process about you.

This Privacy Policy applies to all personal information we gather or process exclusively through your use of www.softic.com (our "Website"), in connection with your relationship with us as a customer or potential customer, partner to our services or supplier. We will only use your personal information in accordance with this Privacy Policy.

This Privacy Policy should be read together with other terms and conditions posted elsewhere on our Website, including our Site Terms available at www.softic.com/terms-conditions.

When you use our services and website and share your personal information with us, you give us your consent to use your personal information as described in our Privacy Policy. However, this consent does not allow us to send you marketing communications without your separate and explicit consent, which we will ask for in item 8 below.

If you do not want us to use your information in this way, please do not give us your consent.

Sometimes, we may make changes to our Privacy Policy. If these changes do not affect how we treat you or the personal information you have provided us, you will be deemed to have accepted them by continuing to use our services and website. However, before sending you marketing communications, we will always ask for your explicit consent.

We reserve the right to apply the amended terms of this Privacy Policy to the information we have already collected, except for marketing communications. We will notify you by email of any changes to our Privacy Policy. Please make sure to read and review this page regularly to stay informed of any changes.

3. How we may collect and/or receive your personal information

This is collected and/or received by us when you:

• Use or access our Website;
• Fill in forms on our Website, including any information you provide when you register, create or modify an online account with us;
• Communicate with us by email, telephone, in writing, through our Website or via social media;
• Use or access our Website (including, but not limited to, traffic data and data in relation to the resources you access);
• Respond to surveys or questionnaires you may be asked to complete;
• Manage recruitment and any employment applications and processes.

In running and maintaining our platform and services we may collect and process the following data:

• When you register for our services or register for information from us (“User”), we collect information such as your name, phone number, e-mail, company details, country, and a password.
• We also collect your IP address, browser type, operating system, mobile carrier, and your ISP, and receive the URLs of sites from which you arrive or leave the SOFTIC website, or sites that have embedded SOFTIC platform technology.
• We collect information through cookies and other technologies that allow us to recognize you and customize your experience.
• As a User you will also be responsible for the other personal data you include in your company profile including the name and job title of any colleagues you include.
• SOFTIC also collects collect and process personal information in the following circumstances:
• When you give us your personal information by phone, email, and via our websites. This includes but isn’t limited to information you give us when you register with us, request information, work with us, request literature, or sign up for newsletters. The information you give us can include your name, address, email address and other contact information. It can also include your financial information and other personal details.
• When you visit our website: we automatically collect information which includes: the Internet Protocol (IP) address used to connect your computer to the internet, your login information, your geographic location, your browser and browser plug-in type and version, and your operating system and platform. We also collect information about your visit, including the source of your visit, and the full click path and mouse movement through our sites (including date and time). This includes the services you viewed, searches you made on our sites, page response times, download errors, length of visits to certain pages, page interaction information (such as page scrolling, mouse clicks, mouse movements and keyed text), and how you navigated away from any page and any phone number you use to call our support services.
• When we receive your information from third parties: We may receive information about you from third parties such as credit reference agencies, payment service providers, or analytics providers.

If we don’t receive all of the personal information we’ve requested from you, then our partners may not be able to provide services through our platform for your benefit or use your information for business purposes.

We may also collect your personal information from publicly available information such as information on third party websites or from partners and joint ventures and other companies under common control (together, the "Affiliates").

4. What is personal information?

The types of personal information we receive, store and use may include:

• Data provided by you to verify your identity, including your title, name, address, telephone numbers, passport details, email address and date of birth;
• Your account information (including your username and password);
• Your financial details including your bank account details, online banking information, credit or debit card number and transaction and credit information;
• Information about your interactions you may have with us and our staff, including interactions via email, telephone or through our Website;
• Information regarding your personal or professional interests, employment status, demographics, experiences with our products, and contact preferences in order to provide you with further services or information about our products and services;
• Any other information we require to assess your knowledge and experience in investing including your financial situation and investment goals; and
• Records of transactions, dealing & payment instructions and without limitation all data generated through the operation of your account with; our firm, bankers, executing brokers, custodians and professional advisors.

5. Changes in your personal information

From time to time, we may request you to confirm the information we hold to ensure the accuracy and currency of our records. If you become aware of any material changes to your personal data, such as a change of address, name, contact number or email address, we kindly request that you notify us promptly via hello@softic.com. If we determine that such changes may impact the operation or functionality of your account, we may ask you to provide us with documentary evidence to verify the new data.

6. How we use personal information

We collect and use your personal information to understand your needs and improve the services we provide. This includes collecting, storing, and processing your personal information through third-party data processors, agents, and subcontractors who work on our behalf.

We process your data relying on any of the following grounds which apply to the collection and processing of your data: i) consent; or ii) where the processing is necessary for the performance of a contract with you; or iii) to meet our legal compliance obligations; or iv) under the legitimate interests ground. SOFTIC’s legitimate business interest, and purpose of our processing your data, is to provide data and information on the firms and funds in the investment management industry.

Processing your data also allows us to administer your account and customize the service we provide you and other Users as well as to send you service or promotional communications through email and notices on the SOFTIC web platform.

When you receive newsletters or promotional emails from SOFTIC, we'll use personalized unique links or similar technologies to find out if you opened the email and which links you clicked. This helps us to provide you with more targeted email communications or other information that better meet your needs. We'll rely on our legitimate interests to do this, which means we'll use your data to provide electronic direct marketing of our services and products unless the law requires us to obtain your consent. If that's the case, we'll ask for your consent first.

Specifically, we process your data for the following reasons:

• To allow you to use the various features of our Website;
• To provide our platform services to you in connection with our legitimate business interests, including carrying out any obligations specified in any contracts between us;
• For purposes related to providing our platform services to you, including verifying and authenticating your identity, processing your payments, completing transactions and processing your purchasing requests;
• To improve and tailor our platform services and train our staff;
• For our own internal record-keeping requirements;
• To help protect your account and prevent unauthorised access to your account;
• To meet our regulatory & anti-money laundering obligations;
• To assist in the detection, prevention of fraud and financial crime;
• For market research, analysis, testing, monitoring, risk management, audit and administrative purposes;
• To contact you, for example, to send service communications through our Website, email or any other medium such as to notify of material information relevant to our legitimate business interest including when you check your dashboard or when financial transfers (receipts or payments) have been made on your behalf;
• Where you have provided your explicit consent for us to do so, for marketing purposes, such as sending you email newsletters with our and our Affiliates' latest offers, information, promotions or products and services or other information we think you may find interesting or for customer satisfaction purposes in accordance with this Privacy Policy;
• To inform our business decisions, and to deliver a relevant experience;
• If we learn of your insolvency or bankruptcy (or any insolvency proceedings), we will transfer your details to the Official Receiver or appointed insolvency practitioner(s);
• To check instructions you’ve given us or to resolve disputes including to establish, exercise or defend our legal rights;
• To let you know about any changes we make to our platform and services;
• To process any job application you submit, or that an agency submits for you;
• To request your feedback on a product or service via a third party we have chosen (we will only share your name and email address);
• Gathering data for analysis and research, and to provide management information or other services internally and to third parties;
• To administer our sites and for internal operations, including troubleshooting, data analysis, load management, testing, research, statistical and survey purposes;
• To improve our sites to make sure that our content is as effective as we can for you and for the service we provide;
• To allow you to participate in any interactive features of our platform or sites;
• To monitor, record, store and use any telephone, email or other communication with you. We will update your records with any new information you or a third party give us, and we’ll add it to any information we already have;
• When you call us or contact us we’ll collect the information and may keep a copy of the call or email for our records and for security purposes. We’ll also use your information to help improve our efficiency and effectiveness;
• To deal with any enquiries or issues you have about how we collect, store and use your information, or any requests made by you for a copy of the information we hold about you; and
• For internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies.

7. Do we share personal information with anyone else?

We respect your privacy and do not sell, rent, or share your personally identifiable information with third parties unless you give us your consent. However, we may share your information with third-party payment processors to process your payment information and enable us to fulfill your requests for paid services.

We may disclose personal information we collect or receive:

• To you, your lawfully appointed attorney-in-fact or those we reasonably believe to be acting on your behalf;
• To our Affiliates for the purposes described in this Privacy Policy and always in accordance with the terms of this Privacy Policy;
• To third parties to provide a service to, or perform a function for us, or you, or who are otherwise appointed by us in connection with the services we offer including those who are acting as our agent or sub-contractor, including, without limitation, data processing service providers executing brokers, custodians and our legal and professional advisors;
• To third parties in connection with a proposed or actual financing, securitisation, insuring, merger, restructure, sale, acquisition, assignment or other disposal of all or any part of our business or assets or the assets of any Affiliate or to anyone whom we may transfer our rights and/or obligations for the purposes of evaluating / performing the proposed transaction; and
• To any entity to whom we are required by any applicable law, regulation or legal process, to disclose the data. We would advise that on such occasions we may be restricted by law from notifying you of such disclosure.

We want to assure you that we never store or share your financial account login details, including your online banking username and password, with anyone. Additionally, we will never ask you for this information. If you receive any requests for your banking login credentials, please do not provide them. Instead, contact us directly at info@softic.com to report the incident and get the necessary help.

8. Marketing Communications

We will only send you marketing communications via email or text message if you have given us your explicit consent. Such communications may be related to goods, products, services or opportunities which are in our legitimate business interest and are substantially similar to those that you have previously purchased, invested in, or expressed interest in. Alternatively, we may contact you in this way if you have explicitly agreed to it.

Please do not provide us with such consent if you do not want that information to be used by us in this manner.

When you create your account, we will ask if you want to receive marketing messages from us or third parties. You can change your mind later by contacting us at info@softic.com.

If we have your email address but you haven't created an account or asked to receive any marketing messages, we will remove your email address from our records after one year if we don't hear from you. However, if you want us to keep your email address on file, please let us know.

9. Statistical information

We may combine your information with information about other users of our website or services to create statistical data that does not identify you or contain any of your personal data. This data is used solely for analytical purposes and to improve our services. We may share this aggregate information with third parties in the legitimate interests of the business.

10. Information security

We take the security of your personal data very seriously. Appropriate technologies and procedures are used to protect your personal information.

Our data security procedures are always kept up to widely accepted international standards, and we only work with recognized suppliers. Furthermore, we regularly review our policies and update them whenever necessary to ensure your protection, meet our business needs, adapt to changes in technology, and comply with regulatory requirements.

Here are examples of the ways we protect your data:

• We have appropriate technical and organisational measures in place to protect you against accidental loss and unauthorised access, use, destruction or disclosure of your data.
• We have a business continuity and disaster recovery plan that is designed to help us offer our services and protect our people and assets no matter what happens.
• We place appropriate restrictions on access to personal information.
• We implement measures and controls, including monitoring and physical measures, to store and transfer data securely.
• We complete data protection impact assessments in accordance with legal requirements and our business policies.
• We provide data security training for our employees.
• We use a stringent approach to vendor risk management.

As the internet is an open medium, we cannot ensure that any information you send to us via email or our platform will not be intercepted or tampered with. Therefore, any transmission is at your own risk. Once we receive your information, we follow strict procedures and use security features to prevent unauthorized access and ensure the safety of your data.

11. How long do we retain your data?

The duration for which contact details are stored varies depending on the reason and intention for which they were collected. SOFTIC will periodically review your personal data to ensure that it is still necessary to keep it for the intended purpose.

We keep track of "Page View" data, which means we keep a record of which firms have accessed your firm profile on our web product and how frequently they have done so. This data is retained for the lifetime of the product to help us understand changes to usage patterns over time.

Billing data is kept for the lifetime of our contract with you and then ongoing for seven years to comply with tax legislation.

Backups of our products are retained for a year. However, we have processes to ensure if a restore is required Subject Rights are maintained.

Financial data is retained in accordance with statutory and regulatory requirements.

Marketing and sales data is retained and limited in accordance with this policy.

12. Third party links

Our website may provide links to third-party websites, mobile sites, and mobile applications. It's important to note that we strive to work with reputable parties, but we do not have any control over these third-party sites. Therefore, we cannot be held responsible for the protection and privacy of any information you provide while visiting such sites. Each of these sites is governed by its own privacy policies and not by our Privacy Policy. We strongly recommend reviewing their relevant privacy/data protection policy before providing them with any personal data if you have any concerns.

13. Data storage

We may transfer and store personal information that we collect from you to locations outside of Hungary. This information may also be processed by staff who operate outside of Hungary. Please note that countries outside of Hungary may not offer the same level of protection for personal data as Hungary.

However, we will take reasonable steps to ensure that any personal information transferred outside of Hungary will be treated securely and in accordance with our GDPR obligations and this Privacy Policy.

By submitting your personal information to us and using our services or website, you agree that we may transfer, store and process your personal information outside of Hungary.

We take necessary steps to ensure that your data is treated securely and in accordance with our policy. However, it's important to note that the transmission of information over the internet is not entirely secure, and we cannot guarantee the security of any data you transmit to our website via the internet or any other means.

We will retain your personal information and any other relevant information as required by the applicable laws and for operational and legal purposes.

14. Access to information

You have the right to access information that we hold about you under the General Data Protection Regulation (GDPR). To do so, please contact us at info@softic.com and include your name, address, and any other relevant identifying information. We will not charge you for reasonable and periodic requests to access this information.

You have the right to instruct us to safely and securely move, copy or transfer your personal data from one IT environment to another without it affecting its usability. If you request a transfer of your data, we may keep a copy to meet regulatory and statutory obligations. Additionally, we may remove any proprietary information related to the activities of our firm or its affiliates.

15. What are your rights in relation to our use of your information?

You have rights under data protection law in relation to our use of your information, including to:

• Request access to your information, which you can do by emailing info@softic.com stating you are submitting a Subject Access Request;
• Update or amend your information if it is inaccurate or incomplete by emailing info@softic.com requesting an update;
• Object to certain uses of your personal data (which includes direct marketing and processing based on legitimate interests and processing for purposes of scientific or historical research and statistics) on grounds relating to your particular situation by emailing info@softic.com;
• Withdraw any consents you have provided in respect of our use of your information either by clicking unsubscribe links in emails or emailing info@softic.com;
• Request the return of information you have provided to us, to use for your own purposes (often called your right to data portability) where the processing is based on your consent or for the performance of a contract, and the processing is carried out by automated means;
• Lodge a complaint with relevant supervisory authority.

We may need to ask you for further information and identification to help us to comply with this request. If you have any questions about these rights, or you would like to exercise any of them, please contact us at info@softic.com

16. Right to have your data deleted

You have the right to ask us to delete your personal data without undue delay and we shall comply where one of the following grounds applies:

• Your personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
• There is no other legal ground for us processing;
• Your personal data has been unlawfully processed;
• Your personal data must be erased for compliance with a legal obligation in Hungary law to which we are subject (note we will require written evidence of such legal obligation);

Please note that any personal data we hold in relation to the opening and or operation of your account with us may be subject to our record keeping obligations as provided by the authority in Hungary. If you require further information, please email us at info@softic.com.

17. Cookies

Cookies are small files that get stored on your device when you visit our website. We use cookies to recognize you, to improve our website's performance, and to create statistical data based on your preferences.

Cookies generally fall into one of the following categories:

• Strictly necessary cookies which are cookies that are required to allow you to use a website and its features;
• Performance cookies which recognise and collect information about how visitors use a website to create aggregated, anonymous information that does not identify the visitor;
• Functionality cookies which allow the website to remember you and provide a more personalised service to you; and
• Targeting or advertising cookies which are used to deliver adverts relevant to you.

Our website uses different types of cookies – strictly necessary cookies, performance cookies, functionality cookies, and targeting or advertising cookies for which you have given explicit consent. Some of the cookies may be stored on your device between browsing sessions.

If you wish to disable our cookies, you can do so by changing the settings on your browser. However, please note that this may prevent you from using certain features of our website.

18. Contacting us

If you have any questions, comments, or would like to request a copy of your personal information, please contact us at info@softic.com.