Introduction

Noemon Tech Ltd (the "Company") is committed to protecting customers' privacy. This Privacy Policy describes what personal data we collect, use and process and how this information is used in the course of our business.

Customer Data

The Company collects customer data for various reasons, which include:

• The provision of investment and ancillary services;
• To ensure compliance with the provisions of the Prevention and Suppression of Money Laundering and Terrorist Financing Law of 2007-2018;
• For regulatory purposes;
• For marketing purposes;
• For business development;
• For recruitment, employment and payroll; and
• For any other purposes related or connected to the above or for any other purpose that the customer will provide personal data for.

Customer's data includes name, address, identification details, postal and business address, mobile phone number, email, profession, bank account details, social insurance number, tax identification number, certificate of clean criminal record, certificate of non-bank work and other relevant details. This data is used and processed by the Company throughout the validity period of the contract / relationship, in order to provide the requested services, which measures will be executed in accordance with the data as documented in the years and the termination of the termination of the contract / relationship.

Processing Activity

The Company may process the personal data set out above for any of the following purposes:

• To disclose personal data to the Cyprus Securities and Exchange Commission and/or the Central Bank of Cyprus as per the relevant legal requirements;
• To share information that is essential to auditors, legal consultants, operational partners, support services partners and affiliates for the complete provision of the service to the customer;
• To share data with other Group companies, as defined in accordance with the Company's policies;
• For the protection of the customer's vital interests;
• To prevent regulatory violations, connected arrangements, the due legal actions against the customer the detection and prevention of fraud and IT purposes (e.g., cyber-security, data loss prevention);
• To provide regulatory authorities, connected governmental authorities and agencies (either than tax authorities), law enforcement agencies, intergovernmental or supranational bodies, and other third parties with the requisite information;
• To comply with legal obligations, connected arrangements, the requisite regulatory framework and/or of the relevant jurisdictions and as permitted under Cyprus Laws.

General Customer Rights According to European Regulation 2014/679 ("GDPR")

Right of Access: Customers have the right to be informed about the processing of personal data by the Company by:

• Visiting the offices of the Company, completing, and submitting the relevant application form; or
• Requesting via email at admin@noemon-tech.ltd the relevant application form and submitting the said via the same email address.

The right to access is subject to the provisions of the Cyprus data protection legislation and the authentication of the legal subscriber.

Right of Erasure (to be Forgotten)

Customers may request the erasure of any of their Personal Data by:

• Visiting the offices of the Company, completing, and submitting the relevant application form; or
• Requesting via email at admin@noemon-tech.ltd the relevant application form and submitting the said via the same email address.

The right to erasure is subject to the provisions of the Cyprus data protection legislation and the authentication of the legal subscriber.

Data Portability

Customers may exercise the right to data portability by:

• Visiting the offices of the Company, completing, and submitting the relevant application form; or
• Requesting via email at admin@noemon-tech.ltd the relevant application form and submitting the said via the same email address.

Data portability is subject to the provision of the Cyprus data protection legislation and the authentication of the legal subscriber.

Right of Updating, Rectification or Minimisation of Personal Data

Customers may update their Personal Data or request the correction of any inaccurate Personal Data or data minimisation by:

• Visiting the offices of the Company, completing, and submitting the relevant application form; or
• Requesting via email at admin@noemon-tech.ltd the relevant application form and submitting the said via the same email address.

These rights are subject to the provisions of the Cyprus data protection legislation and the authentication of the legal subscriber.

Information Security Measures

The Company maintains strict information security measures and procedures to safeguard customers' Personal Data, in line with our legal obligations.

The Company has implemented a holistic Information Security Management System that effectively safeguards the Confidentiality, Integrity and Availability of customers' Personal Data. The Company endeavours to implement a holistic Information Security Management System to effectively safeguard the Confidentiality, Integrity and Availability of our Customers' data.

Transfers outside the EU/EEA: Customers are informed that the procedures of the Company as at least forth within the EU/EEA and should be EU and/or the EEA. Personal data may be transferred to third countries or international organisations only if adequate level of protection is ensured. In case of transfers to countries outside the EU/EEA, customers' Personal Data should outside the EU/EEA will subsequently accessed by other entities, these shall only be shared when there is an appropriate or adequate level of protection in terms of applicable law and/or with the minimum necessary for the intended purposes, on the condition that all relevant data protection agreements (DPA) are in place and duly signed by the parties.

Contact Information and Complaints

Customers can contact the Company for any information in this Privacy Policy by post at 18 Kyriakos Matsis Victory Tower, Office 201, 1062 Nicosia, Cyprus or by email at admin@noemon-tech.ltd. The latest contact details may be found on our website www.noemon-tech.ltd.

The Company has appointed a Data Protection Officer ("DPO").

Definitions

"Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data, where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its appointment may be provided for by Union or Member State law.

"Personal Data" means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

"Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

"Processor" means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller.