NEWERA CAPITAL MARKETS LIMITED (“the Company / Newera Capital”) is committed to protecting its customers’ and other website users’ (“the Client / the Clients”) privacy and developing technology that gives the Clients the most powerful, satisfying, and safe online experience. This Privacy Policy (the “Policy”) applies to the Newera Capital website and governs data collection and usage. By using the Newera Capital website, the Clients would indicate their consent to the data practices described in this Policy.

COLLECTION OF THE CLIENTS’ PERSONAL INFORMATION

In accordance with applicable Anti-Money Laundering and Counter-Terrorism Financing regulations and laws, Newera Capital has an obligation to collect information and verify the identity of its Clients. This information is referred to as Know Your Client information or KYC information. Specifically, the information we collect for KYC identification may include identity, contact details, National Identifier, Socio-demographic, transactional, financial, contractual, documentary data, etc. Newera Capital will carry out its customer identification and verification procedures.

When submitting a Client’s application form to open a live or demo account with Newera Capital, he/she will be providing entities within the Newera Capital group of companies (collectively, the “Newera Capital Group”), and its affiliated entities with their personal information. By applying for and/or opening a live or demo Newera Capital account, the Client acknowledges and agrees that their consent is voluntarily provided to the Newera Capital Group and its affiliated entities, including Newera Capital Markets Limited.

Personal information refers to any information about the Client that identifies the Client or by which the Client’s identity can reasonably be ascertained.

Newera Capital will also maintain records of all transactions and activities on the Client’s account(s), including, but not limited to, details of liquidations on the Client’s account(s). Newera Capital may also collect information about the Client from publicly available sources such as company registers. At any time, upon request, the Client may gain access to the information Newera Capital holds about the Client. Newera Capital may also record telephone conversations between the Client and persons working for Newera Capital. Such recordings, or transcripts from such recordings, may be used to resolve any dispute between the Client and Newera Capital and with a view to satisfying Newera Capital’s statutory obligations, including requests from regulators and other government bodies. Newera Capital will also collect and hold information about the Client when the Client completes an online application or other type of form or operates and deals on the Client’s Account through Newera Capital’s websites.

Newera Capital may collect sensitive information about a Client if:

• The collection is required or authorized by applicable laws or court/tribunal order;
• The Client consents to the collection and the information is reasonably necessary for Newera Capital’s functions and activities;
• Newera Capital reasonably believes that collection is necessary to lessen or prevent a serious threat to the life, health, or safety of an individual or the public, and it is unreasonable or impracticable to obtain the Clients’ consent to the collection;
• Newera Capital has reason to suspect that unlawful activity or misconduct of a serious nature that relates to Newera Capital’s functions or activities is being or may be engaged in;

• Newera Capital believes that the collection is reasonably necessary to assist in locating a person who has been reported as

The Clients are not directly imposed to give Newera Capital their personal information in the application forms. However, without the information required, Newera Capital may not be able to open an account and/or provide services to them. While Newera Capital makes every effort to ensure that all information it holds about Clients is accurate, complete, and up to date, Clients need to notify Newera Capital promptly if there are any changes to the Clients’ personal information. Should the Clients have any questions or complaints about their privacy, the Clients should contact Newera Capital . From time to time, Newera Capital may receive personal information about the Clients’ from third-party sources, but only where Newera Capital has checked that these third parties either have their consent or are otherwise legally permitted or required to disclose their personal information to us. Newera Capital uses the information received from these third parties to enhance services provided to the Clients, such as providing curated content that is relevant to services and topics they are interested in.

When the Clients visit Newera Capital website, Newera Capital may collect certain information automatically from the Clients’ devices. In some countries, including countries in the European Economic Area (EEA) and PRC, this information may be considered personal information under applicable data protection laws. Specifically, the information collected automatically may include information like the Clients’ IP address, device type, unique device identification numbers, browser-type, broad geographic location (for example, country or city-level location), and other technical information. Newera Capital may also collect information about how the Clients’ devices interact with Newera Capital website, including the pages accessed and links clicked. Collecting this information enables Newera Capital to better understand the visitors who come to its website, where they come from, and which content at Newera Capital website they are interested in. Also, Newera Capital uses this information for its internal analytics purposes and to improve the quality and relevance of Newera Capital website. Newera Capital encourages the Clients to review the privacy policies of websites they choose to link so that they can understand how those websites collect, use, and share the Clients’ information. Newera Capital is not responsible for the privacy policies or other content on websites outside of the Newera Capital (and its sister Companies) websites. In all cases, Newera Capital strives to limit the amount of information to be collected and stored to only those that are necessary, so that it could provide the Clients with the relevant services.

USE OF THE CLIENTS’ PERSONAL INFORMATION

Newera Capital collects and uses the Clients’ personal information to operate its website and deliver the services that the Clients need. Newera Capital also uses the Clients’ personally identifiable information to inform them of other products or services offered by Newera Capital and its affiliates. Newera Capital does not sell, rent, or lease its customer lists to third parties. Newera Capital may, from time to time, contact the Clients on behalf of external business partners about a particular offering that may be of their interest. In those cases, the Clients’ unique identifiable information (e-mail, name, address, telephone number) is not transferred to the third party. In addition, Newera Capital may share data with trusted partners for a business purpose, for instance, to perform statistical analysis, send them email or postal mail, provide customer support, amongst others. All such third parties are prohibited from using the Clients’ personal information except to provide Newera Capital related services and

they are required to maintain the confidentiality of the Clients’ information. Newera Capital does not use or disclose sensitive personal information, such as race, religion, or political affiliations, without the Clients’ explicit consent. Newera Capital keeps track of the websites and pages that the Clients visit within Newera Capital, in order to determine what Newera Capital services are most popular. This data is used to deliver customized content and advertising within Newera Capital to Clients, whose behavior indicates that they are interested in

a particular subject. Newera Capital websites will disclose the Clients’ personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to:

• Conform to the requirements of the law or comply with legal process served on Newera Capital or the website;
• Protect and defend the rights or property of Newera Capital; and,
• Act under exigent circumstances to protect the personal safety of users of Newera Capital, or the

USE OF COOKIES

The Newera Capital website uses “cookies” to help the Clients personalize their online experience. A cookie is a text file that is placed on the Client’s hard disk by a Web page server. Cookies cannot be used to run programs or deliver viruses to their computer.

Cookies are uniquely assigned to the Clients and can only be read by a web server in the domain that issued the cookies to the Clients. One of the primary purposes of cookies is to provide a convenience feature to save the Clients’ time. The purpose of a cookie is to tell the Web server that the Clients have returned to a specific page. For example, if the Clients personalize Newera Capital pages or register with Newera Capital’s website or services, a cookie helps to recall the Clients’ specific information on subsequent visits. This simplifies the process of recording the Clients’ personal information, such as billing addresses, shipping addresses, and so on. When a particular Client returns to the same Newera Capital website, the information he/she previously provided can be retrieved, so that they can easily use the customized Newera Capital website. The Clients have the ability to accept or decline cookies.

Most Web browsers automatically accept cookies, but the Clients can usually modify their browser setting to decline cookies if they prefer. If the Clients choose to decline cookies, they may not be able to fully experience the interactive features of the Newera Capital services or websites visited.

### SECURITY OF THE CLIENTS’ PERSONAL INFORMATION

Newera Capital secures the Clients’ personal information from unauthorized access, use, or disclosure. Newera Capital secures the personally identifiable information that the Clients provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. When Newera Capital transmits personal information (such as a credit card number) to other websites, it is protected through the use of encryption, which includes (but is not limited to) Secure Socket Layer (SSL) protocol.

LANGUAGES

Language of communication between the Company and the Client shall be in English. All binding contractual documentation is available in English. Upon its sole discretion, the Company may communicate with the Client in another language than English; however, in case of any discrepancy between the meanings of any communications and/or meanings, or any other communications forming part of this Policy or any other agreements, information or communication in any other language, the meaning of the English Language version shall prevail. The Company or third parties may have provided the Client with translations of this Policy. The original English versions shall be the only legally binding version. In case of discrepancies between the English version and other translations in the Client’s possession, the original English version provided by the Company on the website shall prevail.

REVIEW OF PRIVACY POLICY

NEWERA CAPITAL MARKETS LIMITED is committed to continuously improving this policy, and it will be reviewed regularly (at least every six months) for effectiveness and updated.

This Privacy Policy is supported by management. NEWERA CAPITAL MARKETS LIMITED commits to providing this policy to all employees and displaying it in its business with clients.