PRIVACY & SECURITY POLICY

PRIVACY & SECURITY POLICY

Prior to offering our services to you, we require you to read this Privacy & Security Policy. Version: 2018 June

Privacy & Security Policy, 2018
PRIVACY AND SECURITY POLICY

1. ABOUT FEDTTM BILLIONAIRES

2. FedTtm Billionaires

2.1 is a registered trading name of IX Capital Group Limited, formerly FedTtm Billionaires Limited, which is authorized and regulated by the Securities Commission. FEDTTM BILLIONAIRES is authorized by SCB to deal, arrange and manage Securities. We help traders and Introducing Brokers achieve their business goals and personal ambitions by offering an extensive portfolio. Our business is built on integrity and trust, offering an industry leading combination of dynamic products, competitive trading parameters and premium, one-on-one service. It is FEDTTM BILLIONAIRES’s mission to enable the personal ambitions and business goals of FOREX traders and IBs, through underpinning dynamic productswithcompetitivetradingparametersandapremiumcustomer experience.

2.2 If you have any questions about this policy or how we collect and use personalinformation about you please contact us usingthecontactdetails providedbelow. We alsohave adedicated Data Compliance Officer, who isresponsible for data compliance issues.

Postal Address: FedTtm Billionaires 109 Church Street, Sandyport Marina Village Nassau, NewProvidence The Bahamas SP- 62756 Phone number: +44 203 713 4490 Email: compliance@FedTtm Billionaires.bs

3. FEDTTM BILLIONAIRES’S COMMITMENT

3.1 FEDTTM BILLIONAIRESiscommitted to protect the privacy ofyour personal and financial information obtained to enable us to provide you with a secure website for you transactions. This policy confirms details how FEDTTM BILLIONAIRES manages the information provided to us by you or a third party in connection with our provision of services to you or which we collect from your use of our services via out website(s) and app(s). FEDTTM BILLIONAIRES will use your personal information in accordance with this Privacy and Security Policy and otherwise in accordance with The Bahamas Data Protection(Privacy ofPersonal Information) Actand the United Kingdom dataprotection legislation(s).

3.2 Dataprotectionregulationsrequirethatthe personalinformationweholdabout you must be:

 Used lawfully, fairly and in a transparent way.  Collectedonly forvalid purposesthatwehaveclearly explained to you andnotusedin anyway thatis incompatible with thosepurposes.  Relevant to the purposes we have told you about and limited only to thosepurposes.  Accurate and kept up to date.  Kept only as long as necessary for the purposes we have told you about.  Kept securely.

4. REASONS FORCOLLECTINGPERSONAL INFORMATION

4.1 FEDTTM BILLIONAIRES collects certain personal information in order that it may meet the needs of its customers. By collecting certain personal information, FEDTTM BILLIONAIRES is able to monitor and improve the services which it offers to its existing and potential customers.

4.2 FEDTTM BILLIONAIRES will use thisinformation forthe following purposes:

 verifying your identity;

 assessing the suitability of the products and services we provide;

 establishing and maintaining your account;

 providing our services to you;

 improving our services;

 regulatory requirements; and

 marketing.

5. PERSONAL INFORMATION COLLECTED FROM YOU

5.1 FEDTTM BILLIONAIRESwillcollectandholdinformationaboutyouwhenyoucomplete anonlineapplication orother type of form or accessand trade on youraccountthrough thiswebsite or anotherservice we provide toyou.Thekind ofpersonalinformationyougive usmayinclude(butisnotlimitedto)name,address, date of birth, passport number, tax identification number, email address telephone number, employment and income information,credit/debitcardinformation,transactionhistoryandfinancial statements.

5.2 FEDTTM BILLIONAIRES may derive information from your use of this website or another service we provide to you and may store this information with your personal profile. This information may include site areas visited, pages viewed, frequency and duration of visits, types of transactions conducted, documents downloaded and otherwebsiteswhichmay have referredyou ortowhich you link.

5.3 By opening an account with FEDTTM BILLIONAIRES and by placing Orders and entering into transactions, you acknowledge that you will be providing personal information (possibly including sensitive data) within the meaningof The BahamasDataProtection(Privacyof PersonalInformation)Actandthe United Kingdom Data Protection Act 1998 orthe General Data Protection Regulation“GDPR” or any other applicable laws and regulations to us, and you consent to the processing of that information by FEDTTM BILLIONAIRES for the purposes of performing its obligations under this Agreement and administering the relationship between you and FEDTTM BILLIONAIRES, including the disclosure of the information to Affiliates both within and outside The Bahamas, EuropeanUnion and/or European Economic Area.

5.4 FEDTTM BILLIONAIRESneedscertaininformation tocarry outanagreementwithyouandyoumustprovidethisin order to enterinto an agreementwith FEDTTM BILLIONAIRES to provide you with products and service. If you do not, we may not be able to offer you any products or services. Mandatory information fields are generally set out in theapplication.

5.5 Other correspondence or interaction (for example by email, telephone, post, SMS or via our website) between you and FEDTTM BILLIONAIRES, will include personal information (such as names and contact details) in that correspondence. This may include enquiries, reviews, follow-up comments or complaints lodged by or against you and disputes with you or your organization.

5.6 FEDTTM BILLIONAIRES may also collect details of phone numbers used to call our company and the date, time and durationofanycalls.PleasenotethatifwerecordyourcallstoorfromFEDTTM BILLIONAIRES,wewillinformyou of this.

6. USE OF PERSONALINFORMATION

6.1 FEDTTM BILLIONAIRESmaykeepandusesuchinformation to complywithanylegalrequirements or if it is necessaryfor our legitimate interestorfor any one ormore ofthe following purposes:

a. Toprovidetheservicestoyouthatyou haverequestedincludingprocessing transactions.

b. To confirm youridentity.

c. Tomaintain your personal profile.

d. To manage youraccount.

e. Tocontactyou whennecessary orappropriateinrelationtotheservicesbeing providedtoyou.

f. Tokeepyouupdatedwhilstyouareacustomer inrelation tomatters suchascontractsyouhavetraded and activities ofFEDTTM BILLIONAIRES.

g. Tomanage and administerthe products andservices provided to you.

h. Toprovideyouwithinformation regarding theproducts andservices offeredbyFEDTTM BILLIONAIRES.

i. Todevelopanunderstandingoftheproductsandservicesthatyoumaybeinterestedinobtainingfrom FEDTTM BILLIONAIRES.

j. Toprovideyouwithinformation oropportunitiesthatwebelievemaybe relevanttoyou.

k. Totailorthe website orotherservicewe provide toyoutoyourneeds andinterests.

l. To create anonymised statistical data.

6.2 YouconsenttoFEDTTM BILLIONAIRESusing yourpersonal informationforthe above-stated purposes.

6.3 Where we use your personal information for marketing purposes to inform you about FEDTTM BILLIONAIRES’s products and services that might be of interest to you, you always have the right to ‘opt out’ of receiving such a communication.

6.4 Youcanexercisetherightatanytime by contacting us usingthedetailsprovided atthestartof thispolicy. Ifwe sendyouanymarketingemails,wewillalwaysprovideanunsubscribeoptiontoallowyoutooptout ofany further marketing emails. If you “opt-out” of our marketing materials you will be added to our ‘suppression list’to ensure we do not accidentally send you further marketing. Where you unsubscribe from anypostalmarketing, you may initially stillreceive some contentwhich hasalreadybeen printed or sent, but we will remove you from any future campaigns. We may still need to contact your administrative for operationalpurposes, butwewillmakesurethatthosecommunications do not includedirectmarketing.

6.5 If youareanexisting customer orare actingasabusiness we useyour contactdetailsasnecessary forour legitimateinterestsinmarketing toyouandmaintaining a listofpotentialcustomers.

6.6 Ifyou arenotanexistingcustomer, andarenotactingasabusiness, wewillonlycontactyouformarketing purposeswithyourconsent(whetherwehavecollectedyourdetailsdirectlyfromyou, orthroughathird party).

6.7 FEDTTM BILLIONAIRES will only use your personal information for the purposes forwhich it collected it assetout in this policy, unless FEDTTM BILLIONAIRES reasonably considers a need to use it for another reason and that reason is compatible with the original purpose. If FEDTTM BILLIONAIRES needs to use your personal information for an unrelated purpose, FEDTTM BILLIONAIRESwillnotifyyou andwillexplain the legalbasis whichallows to do so.

7. DISCLOSURE ANDSHARINGOFPERSONAL INFORMATION

7.1 FEDTTM BILLIONAIRES does not sell, license or otherwise disclose your personal information to third partiesfor marketing purposes.Wedousethirdpartyserviceproviderstosendoutourmarketing,butwe onlyallow them to use thatinformationonourinstructionsandwheretheyhaveagreedtotreattheinformationconfidentiallyand to keep itsecure. FEDTTM BILLIONAIRES may be required to provide your personal information to the SCB and other regulatory and government bodies from time to time in The Bahamas, the United Kingdom and other countries. FEDTTM BILLIONAIRES may also disclose your personal information to:

a. Financial institutions and other similar organizations that it deals with in the course of its corporate activities, or those that are nominated by you.

b. Externalservice providers andprofessionaladvisers(whichmay be locatedoverseas)that provide services to FEDTTM BILLIONAIRES.

c. Any organization at your request or any persons acting on your behalf, including your financial adviser, broker, solicitor oraccountant.

d. Any third parties where thisis necessary to process atransaction or provide serviceswhich youhave requested; oranyauthoritytowhomFEDTTM BILLIONAIRESisrequiredtodisclosesuchinformationbylaw.

7.2 Inthe eventthat FEDTTM BILLIONAIRES is subject to negotiationsforthesaleofitsbusiness(whole orpartyof), or sold to a thirdparty or undergo a re-organization, youagreethatany of yourpersonalinformationwhich we hold may be disclosed to suchparty or itsadvisors as part of any due diligenceprocessforthepurposeof analyzing anyproposedsale orre-organization or transferred tothatreorganizedentity orthirdpartyand used forthe same purposes asyou haveagreedtounderthisAgreement.

8. YOUR RIGHTS

8.1 You are not required to provide any personal information requested by FEDTTM BILLIONAIRES. However, without that information, FEDTTM BILLIONAIRES may be unable to open an account for you, where the information is requested in an applicationform, or to provide you with any otherservices, information or assistanceyou have sought.

8.2 Dataprotectionlawgivesyouanumberofrightswhenitcomestopersonalinformationweholdaboutyou. Thekeyrightsaresetoutbelow.MoreinformationaboutyourrightscanbeobtainedfromtheSCB. Under certain circumstances, by law you have the rightto:

a. Beinformedinaclear, transparentandeasilyunderstandableway abouthowweuseyourpersonal information andabout your rights. Thisis why INIFINOX is providing youwith the information in this policy. If you require any further information about how we use your personalinformation, please let us know.

b. Request an accessto your personal information (commonly known as a “data subject accessrequest”). Thisenables you to receiveacopy ofthe personalinformation FEDTTM BILLIONAIRES holds aboutyouand to check that FEDTTM BILLIONAIRES is lawfully processing it. FEDTTM BILLIONAIRESmaycharge a nominalfee to coverthecost of verifying theapplicationandlocating,retrieving, reviewing and copying any materialrequested.

c. Request acorrection of the personal information that FEDTTM BILLIONAIRES holds about you. This enables youto have any incomplete orinaccurate information we hold about you corrected.

d. Request an erasure of your personal information. This enables you to ask FEDTTM BILLIONAIRES to delete or remove personalinformation where there is no good reason for uscontinuing to processit(for instance, we may need to continueusingyourpersonaldata to complywith ourlegalobligations). Youalsohavetheright to ask us to delete or remove your personal information where you have exercisedyourrighttoobject to processing (see below).

e. Object to processing of your personal information where FEDTTM BILLIONAIRES is relying on a legitimate interest (or thoseofathirdparty) andthere issomethingaboutyour particularsituationwhichmakes you want to object to FEDTTM BILLIONAIRES using your information on this basis and FEDTTM BILLIONAIRES does not have a compelling legitimate basis for doing so which overrides your rights, interests and freedoms (for instance, we may need it to defend a legal claim). You also have the right to object where FEDTTM BILLIONAIRES is processing your personal information for direct marketing purposes.

f. Request a restriction for processing your personal information. This enables you to ask FEDTTM BILLIONAIRES to suspendthe processing ofpersonalinformation aboutyou, forexample ifyouwant FEDTTM BILLIONAIRES toestablish its accuracy orthe reason for processing it.

g. Request a transfer of your personalinformation to another party where you provided it to TRADE INFINY and FEDTTM BILLIONAIRES is using it based on your consent, or to carry out a contract with you, and FEDTTM BILLIONAIRESprocesses it using automatedmeans.

h. Withdrawaconsent.InthelimitedcircumstanceswhereFEDTTM BILLIONAIRESisrelyingonyourconsent(asopposed to theotherbasesset out above) to thecollection, processingandtransfer ofyourpersonalinformation for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once FEDTTM BILLIONAIRES has received notification that you have withdrawn your consent, FEDTTM BILLIONAIRES will no longer process your information for the purpose or purposes you originally agreed to, unless FEDTTM BILLIONAIRES has anotherlegitimate interestin doing so.

i. Lodge a complaint. If you think that FEDTTM BILLIONAIRES is using your information in a way which breachesdata protectionlaw,pleasecontactusinthefirstinstanceusingthecontactdetailsprovided in section 1.2 of this Policy. You also have the right to raise a complaint with your national data protectionsupervisory authority (if you are in the United Kingdom,this will be the ICO).

9. UPDATING YOURINFORMATION

9.1 You may inform FEDTTM BILLIONAIRES at any time that your personal details have changed or that you wish FEDTTM BILLIONAIRES to review, verify, correct or request erasure of your personal information, withdraw your consent to the processing or requestthat we transfer a copy of yourpersonalinformation to anotherparty. Please contact us via email at compliance@FedTtm Billionaires.bs.

9.2 FEDTTM BILLIONAIRES will change or delete your personal information in accordance with your instructions, except to the extent that we are required to hold your personal information for regulatory or legal purposes, to provide you with the services you have requested or to maintain adequate business records.

10. ACCESSING YOURINFORMATION

10.1 Under The Bahamas and United Kingdom data protection legislation, you have, subject to certain exceptions, The right to obtain copiesof any personalinformationwhichFEDTTM BILLIONAIRESholds about,thepurposes for which they are being or are to be processed, and the recipients or classes of recipients to whom such information is or may be disclosed. You are entitled to inform FEDTTM BILLIONAIRES of anyinaccuracy inyourpersonal information.

10.2 If you wish to access any personal information FEDTTM BILLIONAIRES may hold or wish FEDTTM BILLIONAIRES to correct any misinformation please notify us in writing using the address provided at the start of this policy. FEDTTM BILLIONAIRES may charge a fee (details of which are available upon request) for providing access to the information to cover the cost of verifying the application and locating, retrieving, reviewing and copying any material requested.

10.3 FEDTTM BILLIONAIRES may need to request specific information from you to help to understand the nature of your request, to confirm your identity and ensure your right to access the information (or to exerciseanyof your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

10.4 Please consider your request responsibly before submitting it. FEDTTM BILLIONAIRES will respond to your request as soon as possible. Generally, this will be within one month from the date your request was received,ifthe requestis going to take longerto dealwith, FEDTTM BILLIONAIRES will let you know.

10.5 If you make a written request to us, we will also correct, delete and/or block personal information from furtherprocessing ifthatinformation provesto be inaccurate.

10.6 Please note that pursuant to The Bahamas Data Protection (Privacy of Personal Information Act and the United Kingdom Data Protection Act 1998) or the General Data Protection Regulation or any other applicable laws and regulations, certain information may be exempt from disclosure or FEDTTM BILLIONAIRES may be unable to disclose information you request.

11. COOKIES AND WEBSITE INFORMATION

11.1 FEDTTM BILLIONAIRES uses cookies (and other tools such as webpage counters or other analytics tools) to gather information about your access to this website and other services we provide to you. Cookies are small piecesofinformation which useauniqueidentification tagandarestoredonyourdeviceasaresult of you using this website or other service we provide to you. FEDTTM BILLIONAIRES uses this as necessary for our legitimate interestsinadministeringourwebsiteand to ensure it operateseffectivelyandsecurely.

11.2 We,orthirdpartyadvertisers,mayalsousethisinformation toserveadverts onyou.Wherethoseadverts are targeted, this may involve using website information and information we (or our third party advertisers) have obtained from third parties. Thiswill notinclude information such asyour nameor contact details. Whereouradvertsare displayedto youusingyourinformation, yourinformation is usedas necessaryforour legitimate interests in marketing to you.

11.3 Wekeepthiswebsiteinformation aboutyouuntiltherelevantcookieexpires orisremovedby you.

11.4 When cookies are used by us, they collectstatistical and factual information about how you use our services. Mostinternet browsersare setup toacceptcookies. If youdonot wishtoreceivecookies, you maybe abletochangethesettings ofyourbrowser torefuseallcookies ortohaveyour computer notify you each time a cookie issent to it, and thereby give yourself the choice whether to accept it or not. However,thismayimpairthequalityoftheservicesthatweprovidetoyou inrelationtoyouraccount.

11.5 Ourwebsitemay,fromtimetotime,containlinkstothirdpartywebsites,plug -insandapplications.Clicking on thoselinksorenablingthoseconnectionsmayallowthirdparties tocollector sharedataaboutyou. We do not controlthese third party websites and are not responsible for their privacy statements. When you leave our website,we encourageyou toread the privacy policy of everywebsite youvisit.

12. CONTENT INFORMATION

12.1 ThisisinformationaboutyouwhichyouprovidewhenyoupostcontentonFEDTTM BILLIONAIRES’s website,social media andanyotherTRADE INFINY’ssites.Thismayincludereviews,photographs,videosandothercontent.

12.2 We may display and publish thisinformation on our platforms as part of our contract with you or as necessary forourlegitimate interestsinproviding contenttoourusers.

12.3 Thisinformation is keptfor aslong as you have anaccountwith us andmay be retainedanddisplayed indefinitely after you close your account.

13. INFORMATIONCOLLECTED ATOURPREMISES

13.1 VISITOR INFORMATION FEDTTM BILLIONAIRES collects information about visitors to our premises. FEDTTM BILLIONAIRES may recordinformationon your visit, including the date and time, who you are visiting, your name, employer, contact details and vehicle registration number. If you have an accident at our premises, thismay include a record of youraccident.

13.2 CCTV FEDTTM BILLIONAIRES may operate CCTV at our premises which may record you and your activities. We display notices to make it clear what areas are subject to surveillance. We only release footage following a warrant or formal request from law enforcement, or as necessary in relation to disputes.

13.3 FEDTTM BILLIONAIRES usesthisinformation as necessary for our legitimate interests in administering your visit, ensuring site security and visitorsafety, and administering parking.

14. STORAGE OFINFORMATION

14.1 FEDTTM BILLIONAIRES’s office headquarters are based in the United Kingdom with a main data centre located in the United Kingdom also. However, where required to perform our contract with you or for our wider business purposes, theinformation that we hold aboutyoumay be transferred to, and stored at, a destination outside theUnited Kingdomand the EU.

14.2 Youacknowledgeandagreethatyourpersonalinformationmaybetransferredwithinoroutsidethe The Bahamas, United Kingdom and European Economic Area(EEA). Youagree thatwe willbe permitted, ifso required, to furnish relevant information concerning or your Trading Account(s) to any person who we believe to be seekingareferenceorcreditreferenceingoodfaith.Theinformationwesharemayaffect your ability to obtain credit. Please note that FEDTTM BILLIONAIRES only transfers personal information to organizations outside The Bahamas if FEDTTM BILLIONAIRES has assessed the organization as having appropriate controls and safeguardsin place to protect your personal data.

14.3 Somecountriesor organizationsoutside of The Bahamas,United Kingdomandthe European Unionwhich we may transfer your information to will have an “adequacy decision” in place, meaning The Bahamas considers them to have anadequate data protection regime in place. Data may be transferred to,stored andprocessed incountrieswhich donotoffer“adequateprotection” forthepurposesofDirectivesofthe SCBforanypurposerelated to theoperation of your Account. Such purposesinclude theprocessingof instructions and generation of confirmations, the operation of control systems; the operation of management information systems; the carrying out of such credit and identity checks as we may deem necessary or desirable; and allowing staff of any of our Affiliates who share responsibility for managing your relationshipfromotherofficestoview informationaboutyou.Youagreethatwhere itisnecessary for the provision of these or other Services to you, we may transfer your information to persons who provide services to FEDTTM BILLIONAIRES, including where those persons may be outside the EEA. You consent to FEDTTM BILLIONAIRES’s processing and disclosing such information in accordance with FEDTTM BILLIONAIRES’s Privacy and Security Policy published on FEDTTM BILLIONAIRES’s website(s), as may be updated from time to time.

14.4 If we transferdata to countries ororganizations outside of The Bahamas thatdoes nothave anadequate dataprotection regime in place, we willensure thatappropriate safeguards(forexample, model clauses approved by the EU or a data protectionauthority) are put in place where required. To obtainmore details of these safeguards, please contact us.

15. DATASECURITY

15.1 FEDTTM BILLIONAIREStakessecurityveryseriously and adoptsindustryandinformationsecuritybestpracticesto protect your personal information and ensure it is not accessed by unauthorized persons. Measures include encryption ofdataduringtransmission,strong authentication mechanisms and secure access to machines and data.

15.2 FEDTTM BILLIONAIRES has put in place appropriate internal security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, FEDTTM BILLIONAIRES limits access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on FEDTTM BILLIONAIRES’s instructions and they are subject to a duty of confidentiality.

15.3 TRADE INFINYhas put in placeprocedures to dealwithanysuspecteddatasecuritybreachandwillnotifyyou and any applicable regulator of a suspected breach where necessary.

16. RETENTION OFINFORMATION

General retentionpolicy

16.1 To determine the appropriate retention period for personal information, we consider the amount, nature, ands sensitivityof thepersonalinformation, the potential risk of harm from unauthorized use or disclosure of yourpersonalinformation, thepurposesforwhich we processyourpersonalinformation andwhetherwe canachievethosepurposesthroughothermeans, andtheapplicablelegalrequirements.

16.2 Generally,FEDTTM BILLIONAIRESwillkeepyourinformationforaperiodoffive(5)years.Insomecircumstances,it maybe necessary to keepyour information forlonger than thatinorder to fulfilthe purposes we collected itfor, includingforthepurposes ofsatisfyinganylegal,accounting,orreportingrequirements. Legal Claims

16.3 Where FEDTTM BILLIONAIRES considers there to be a risk to defend or bring legal claims, FEDTTM BILLIONAIRES may retainyourpersonalinformationasnecessaryforalegitimateinterestsinensuringthat FEDTTM BILLIONAIREScan properly bring or defend legal claims. FEDTTM BILLIONAIRES may also need to share this information with insurers or legaladvisers. How long FEDTTM BILLIONAIRES keeps this information for will depend on the nature of the claim and how long FEDTTM BILLIONAIRES considers there to be a risk that we willneed to defend or bring a claim.

16.4 In some circumstances FEDTTM BILLIONAIRES may anonymize your personal information so that it can no longer be associatedwith you, in whichcase FEDTTM BILLIONAIRES may use such information withoutfurthernotice toyou.

17. YOURCONSENT

17.1 Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By accessingthis website or otherservice we provide to you, you consent toFEDTTM BILLIONAIRES collecting, maintaining, using and disclosing personal information about you and provided by you or by another person as described above.

18. AMENDMENTS TOPOLICY

18.1 FEDTTM BILLIONAIRESmaymakechanges to this Privacyand Security Policyfrom time to timeforanyreasonand will notify you of such changes by posting an updated version of this policy on this website or where appropriate, byemail.

18.2 Youareresponsibleforregularlyreviewingthis Privacyand Security Policyand if youusethiswebsite orother serviceweprovidetoyouafteranychangesarepublished,anysuchuseshallconstitute your agreement to thosechanges.