The types of personal information we may collect include:

• Full name
• Residential address
• Contact details (e.g., telephone number, email address)
• Date of birth, place of birth, gender, and citizenship
• Financial details, including income, wealth, source of funds, assets, liabilities, bank account information, trading statements, and financial statements
• Trading account details, including balances, trading activity, inquiries, and responses
• Employment and professional information
• Authentication data, such as a signature
• Location data
• Trading knowledge and experience, including performance
• Verification information, such as identification documents (e.g., passport, driver’s license) and other details required to confirm your identity (e.g., identification numbers, tax registration numbers, and background checks from public records or third-party entities)

Other identifiable information necessary for providing our services to you, including details about your trading experience.

We may collect this information:

• Through your use of our services and platforms (websites, applications, and trading systems)
• Account opening and demo account registration forms
• Customer service interactions
• Information provided by third parties, such as payment service providers and publicly available sources
• Additionally, we may maintain records of your trading behavior, including:
• Products traded, along with their performance
• Historical data, such as past trades and investments, including the amounts invested
• Preferences for specific types of products or services

If you choose not to provide certain required information, we may be unable to fulfil your request for a specific product or service.

We may also record communications with you (including electronic, telephone, in-person, or other interactions) related to our services and business relationship. These recordings will be the property of Cubo Markets Ltd and may serve as evidence of communications. Such recordings may occur without the use of a warning tone or additional notification.

Processing of Your Personal Information

We may process your personal data based on the following grounds and for the following purposes:

1. Performance of a Contract

We process personal data to provide our services and products and to deliver information about them, as part of the contractual relationship we establish with our clients. This includes fulfilling our contractual obligations and completing client onboarding and acceptance procedures. To achieve this, we must verify your identity to accept you as a client. We use your personal data to effectively manage your trading account with us, which may involve engaging third parties to conduct credit or identity checks on our behalf. This processing is essential for ensuring compliance with legal and regulatory requirements, such as ‘Know Your Customer’ (KYC) and customer due diligence (CDD) obligations.

2. Compliance with a Legal Obligation

Cubo Markets Ltd is subject to various legal obligations and statutory requirements under applicable laws, including but not limited to anti-money laundering (AML) laws, financial services regulations, corporation laws, privacy laws, and tax laws. Additionally, we must comply with the directives of supervisory authorities that govern our operations. To meet these obligations, we may process your personal data for activities such as:

• Performing credit checks
• Conducting identity verification
• Processing payments
• Complying with court orders
• Meeting tax reporting or other regulatory requirements
• Implementing anti-money laundering controls

3. For the Purposes of Safeguarding Legitimate Interests

We process personal data to safeguard the legitimate interests pursued by Cubo Markets Ltd or third parties. A legitimate interest arises when we have a valid business or commercial reason to use your personal information. Examples of such processing activities include:

• Initiating legal claims and preparing our defence in litigation or dispute resolution procedures
• Implementing risk management measures
• Developing and improving our business operations, products, and services
• Ensuring IT and system security, which includes measures to prevent potential crimes, ensure asset protection, and enforce admittance controls
• Sharing your personal data within Cubo Markets Ltd to update or verify information in compliance with applicable anti-money laundering (AML) frameworks

4. You Have Provided Your Consent

The storage and use of your personal data by Cubo Markets Ltd may also be based on your explicit consent, except where other legal grounds apply as described in this Privacy Policy. Your consent enables us to process your personal data for specific purposes agreed upon by you.

You have the right to revoke your consent at any time. However, any processing of your personal data that occurred before the receipt of your revocation will remain lawful and unaffected.

5. To Provide You with Products and Services, or Information About Our Products and Services, and to Review Your Ongoing Needs

Once you successfully open a trading account with Cubo Markets Ltd or subscribe to updates from us, we may need to use your personal information to deliver our services and fulfill our obligations to you. Additionally, it is in our legitimate interest to ensure that we are offering you the best possible products and services. To achieve this, we may periodically review your needs based on our assessment of your personal information.

6. To Investigate or Settle Enquiries or Disputes

We may use the personal information collected from you to investigate issues or resolve disputes that arise between you and Cubo Markets Ltd. It is in our legitimate interest to ensure that all enquiries and disputes are addressed and resolved promptly and efficiently.

7. To Comply with Applicable Laws, Court Orders, Other Judicial Process, or the Requirements of Any Applicable Regulatory Authorities

We may process your personal information to comply with applicable laws, regulations, court orders, or other judicial processes, as well as to fulfill the requirements of relevant regulatory authorities.

8. Data Analysis

Our webpages and emails may include web beacons, pixel tags, or similar data analysis tools that enable us to track the receipt of communications and count the number of users who visit our webpages or interact with our correspondence. We may also aggregate your personal information, such as trading history, with data from other clients on an anonymous basis to analyze trends and improve our offerings.

9.Marketing Purposes

We may use your personal information to send you marketing communications through email, phone, SMS, or other channels (such as social media) to keep you informed about our latest products and services. Cubo Markets Ltd will not disclose your personal information to external parties in a way that allows them to market directly to you. If you wish to opt-out of receiving marketing communications from us at any time, you can follow the instructions provided in the communication or contact us directly.

10. Internal Business Purposes and Record Keeping

We may use your personal information for internal business processes, research, and record-keeping purposes. This processing aligns with our legitimate interests and is essential for complying with our legal obligations. This may include maintaining records of any communications we have with you regarding the products and services we provide.

11. Legal Notifications

In certain situations, the law requires us to notify you of changes related to our products, services, or applicable legal and regulatory requirements. You will continue to receive such important notifications from us even if you choose to opt-out of receiving direct marketing communications.

12. Physical Security

If you visit any of Cubo Markets Ltd’s premises, we may record your image using CCTV systems for security purposes. Additionally, we may collect your details to maintain a record of individuals who have accessed our premises on a given day.

Disclosure of Your Personal Information

Cubo Markets Ltd is committed to protecting the confidentiality of our clients’ information and will not disclose it to third parties except in the following cases:

• When required by applicable laws, regulations, or rules.
• If there is a legal duty to disclose.
• When it aligns with our legitimate business interests; or
• At your request, with your consent, or as outlined in this policy.
• As part of using your personal data for the purposes outlined in this Privacy Policy, we may disclose your personal information to:
• Any companies related to Cubo Markets Ltd
• Our associates and service providers, such as administrative, financial, legal, tax, compliance, insurance, and research professionals
• Business introducers, with whom we have mutual relationships
• Credit providers, courts, tribunals, and regulatory authorities, as permitted or required by law

Anyone authorized by you

If we disclose your personal information to business partners, such as payment processors or banks, to fulfil the services you request, these third parties may retain your information to comply with their legal and regulatory obligations.

International Transfers of Personal Data

Cubo Markets Ltd may transfer your personal information outside your home country to affiliated companies and service providers engaged on our behalf. If such transfers occur, we ensure that they are lawful and that appropriate safeguards are in place to protect your personal data.

By submitting your personal data, you consent to its processing by Cubo Markets Ltd staff operating outside your home country who assist us in fulfilling your requests, processing your payment details, or providing support services. We take all reasonable steps to ensure that your data is handled securely and in compliance with this Privacy Policy.

Cookies

Cookies are small text files sent from our website(s) to your browser and stored on your computer’s hard drive. They help us:

• Improve the performance of our website(s) and user experience
• Track referrers to our website(s)
• Improve advertising campaigns and enable remarketing efforts

We use cookies for remarketing to reconnect with users who have previously visited our website(s) or expressed interest in our products and services. You may opt out of this specific use of cookies by visiting Google Ads Settings.

Types of Cookies We Use

Session ID Cookies: These expire after a set amount of time or when you close your browser window.

Persistent Cookies: These remain on your hard drive for a longer period and can be manually removed through your browser’s help settings.

For further details about our cookie policy, please read our Cookies Policy.

Storage of Your Personal Information and Retention Period

Your personal information will be stored securely in a combination of computer-based storage systems, paper-based files, and other records. We will retain your personal information for as long as we maintain a business relationship with you. When we determine that personal information is no longer required for the purposes it was collected, we will either anonymize the data or securely destroy the records.

In compliance with legal and regulatory obligations, certain personal information may need to be retained for extended periods after the business relationship has ended, including:

Anti-Money Laundering (AML) Requirements: We are required to retain customer due diligence documents and transaction records for a period of 5 years after our business relationship ends.

Communication records: Personal information recorded through communication channels may be retained for up to 7 years or longer if necessary for legitimate purposes, such as resolving disputes.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws regarding your personal data:

Request access: to your personal information (a “data subject access request”)

Request correction: of your personal information

Request erasure: of your personal data

Object to processing: of your personal data

Request restriction of processing: of your personal data

Right to data portability: to obtain and reuse your personal data for your own purposes across different services

If you wish to exercise any rights, please email us at support@fascocapital.com.

You will not have to pay a fee to access your personal data or exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.

We may need to request specific information from you to help us confirm your identity. We try to respond to all legitimate requests within one month.

Personal Data Breach

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of any breach where we are legally required to do so.

How to Contact Us

If you have any questions or concerns regarding this Privacy Policy, please feel free to contact us by emailing support@fascocapital.com.

We are here to address your inquiries and ensure your privacy-related concerns are resolved promptly.

Cubo Markets Ltd.
Company Registration Number: 2026-00241
Registered Office: Ground Floor, Sotheby Building, Rodney Bay, Gros-Islet, St Lucia, LC01 101
Physical Office: Office 16, 25 Corinth Hilltop, Corinth, Gros-Islet, St Lucia, LC01 101