At European Maritime Finance, we understand that confidentiality and security of the personal information (“Personal Information”) that you share with us is important. European Maritime Finance affiliates (collectively, “EMF”), is committed to protecting the privacy of Personal Information, including Personal Information related to individuals who may be customers, employees, agents, job applicants or others inside or outside of EMF. That is why we have developed specific policies and practices designed to protect the privacy of your Personal Information. By opening an account at EMF or by utilizing the products, services and applications available through EMF, you have consented to the collection and use of your Personal Information in accordance with this privacy policy (“Privacy Policy” or “Policy”). We encourage you to read this Privacy Policy carefully.

This Policy is based on the privacy and data protection principles common to the countries in which we operate. This Policy is intended to summarize EMF’s data protection practices generally and to advise our customers, prospective customers, job applicants, website visitors and other third parties about EMF’s privacy policies that may be applicable to them.

This Policy is specifically addressed to those who provide Personal Information to EMF or who visit or use EMF’s websites, trading platforms, software application and social media sites.

EMF is responsible for the Personal Information that we may collect in the manner discussed below. EMF includes: EMF, Rue Lion d’Or 6, 1003 Lausanne, Switzerland; EMF, Kongens Nytorv 22, 1050 Copenhagen, Denmark and their respective affiliates (the “EMF Entities”). Specifically, your Personal Information will be controlled by the EMF Entity that is providing services or communication to you. In some instances, your Personal Information will be controlled by more than one EMF Entity.

EMF collects and processes Personal Information from you. This may include, among other things, information:

provided during the EMF account application process or during use of any of EMF’s website applications (for example, your name, email address, telephone number, birth date, tax ID number, investment objectives, etc.);

acquired as a result of the transactions you conduct through the EMF systems or in connection with services offered by EMF (for example, if you participate in EMF’s asset management program);

received from consumer-reporting agencies;

collected through Internet cookies (for further information on our use of cookies, please see our Cookie Policy).

In order for you to utilize our services, you will provide us with your Personal Information entirely voluntarily. In most circumstances EMF cannot take action without utilizing certain of your Personal Information, for example, because this Personal Information is required to process your instructions or orders or provide you with access to our services or marketing materials. In most cases, it will be impossible for us to provide the services to you without the relevant Personal Information.

We may use your Personal Information for the following purposes (“Permitted Purposes”):

To provide you with brokerage and other services available on our platforms, and/or to deal with any requests or inquiries you may have;

To pursue legitimate interests, including to carry out, monitor and analyze our business or operations;

To conduct our recruiting processes;

To contact you (unless you tell us that you prefer us not to) regarding features and functionality that may be of interest to you;

To enter into or carry out contracts of various kinds;

To conduct monitoring by us or any other person on our behalf using various methods, including: (i) the use of “intelligent” automated monitoring tools; or (ii) through random monitoring of systems, for example systematically via electronic communication recording tools; (iii) specific monitoring of systems for example in relation to investigations, regulatory requests, subject access requests, litigation, arbitration or mediation or; (iv) data tracking, aggregation and analysis tools that pull data from various disparate data sources to draw linkages and/or detect behavioural patterns, interactions or prefere

We may use your Personal Information for the following purposes (“Permitted Purposes”):

To provide you with brokerage and other services available on our platforms, and/or to deal with any requests or inquiries you may have;

To pursue legitimate interests, including to carry out, monitor and analyze our business or operations;

To conduct our recruiting processes;

To contact you (unless you tell us that you prefer us not to) regarding features and functionality that may be of interest to you;

To enter into or carry out contracts of various kinds;

To conduct monitoring by us or any other person on our behalf using various methods, including: (i) the use of “intelligent” automated monitoring tools; or (ii) through random monitoring of systems, for example systematically via electronic communication recording tools; (iii) specific monitoring of systems for example in relation to investigations, regulatory requests, subject access requests, litigation, arbitration or mediation or; (iv) data tracking, aggregation and analysis tools that pull data from various disparate data sources to draw linkages and/or detect behavioural patterns, interactions or preferences for analysis (including predictive analysis); and/or (v) using other similar monitoring technology that may become available from time to time;

To comply with applicable laws or regulations in any country;

For any other purpose for which your Personal Information was provided to us.

nces for analysis (including predictive analysis); and/or (v) using other similar monitoring technology that may become available from time to time;

To comply with applicable laws or regulations in any country;

For any other purpose for which your Personal Information was provided to us.

To communicate with you through the channels you have approved to keep you up to date on the latest developments, announcements and other information about IBKR services, products and technologies;

To conduct customer surveys, marketing campaigns, market analysis, or promotional activities;

To collect information about your preferences to create a user profile to personalize and foster the quality of our communication and interaction with you (for example, by way of newsletter tracking or website analytics).

Where legally required, with regard to marketing-related communication, we will only provide you with such information after you have opted in and we will also provide you with the opportunity to opt out at any time if you do not wish to receive further marketing-related communication from us. We like to keep our customers, personnel and other interested parties informed of company developments, including news relating to EMF that we believe is of interest to them. If you do not wish to receive publications or details of events or seminars that we consider may be of interest to you, please let us know by following this link: https://www.maritimefinance.dk. Where legally required, we will not use your Personal Information for taking any automated decisions affecting you or creating profiles other than described above.

Depending on which of the above Permitted Purposes we use your Personal Information for, we may process your Personal Information on one or more of the following legal grounds:

Because processing is necessary for the performance of a client instruction or other contract with you or your organization;

To comply with our legal obligations (for example, to keep pension records or records for tax purposes);

Because processing is necessary for the purposes of our legitimate interest or those of any third party recipients that receive your Personal Information, provided that such interests are not overridden by your interests or fundamental rights and freedoms.

Because processing is useful or necessary in our discretion, and is not prohibited under the law of the relevant jurisdiction.

In addition, the processing may be based on your consent where you have expressly given that to us.

We may share your Personal Information in the following circumstances:

We may share your Personal Information between the EMF Entities on a confidential basis as allowed by applicable law or where required for the purpose of providing products or services and for administrative, billing and other business purposes. A list of the countries in which EMF Entities are located can be found on our website;

We may share your Personal Information with companies providing services in the areas of fraud and crime prevention and with companies providing similar services, including financial institutions such as credit reference agencies and regulatory bodies;

We may share your data with third parties to assist us with the conduct of our recruitment processes;

Consistent with applicable law, we may share your Personal Information with courts, law enforcement authorities, regulators or attorneys or other parties for the establishment, exercise or defence of a legal or equitable claim or for the purposes of a confidential alternative dispute resolution process;

We may also use aggregated Personal Information and statistics for the purpose of monitoring website usage in order to help us develop our website and our services.

Otherwise, we will only disclose your Personal Information when you direct us or give us permission to do so, when we are allowed or required by applicable law or regulations or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities

If you provide Personal Information to us about someone else (such as one of your directors or employees or someone with whom you have business dealings), you must ensure that you are entitled to disclose that Personal Information to us and that, without our taking any further steps, we may collect, use and disclose that Personal Information as described in this Privacy Policy. In particular, you must ensure that the individual concerned is aware of the various matters detailed in this Privacy Policy, as those matters relate to that individual, including our identity, how to contact us, our purposes of collection, our Personal Information disclosure practices (including disclosure to overseas recipients), any right the individual may have to obtain access to the Personal Information and make complaints about the handling of the Personal Information and the consequences if the Personal Information is not provided (such as our inability to provide services).

To the extent required by law, we will take appropriate technical and organizational measures to keep your Personal Information confidential and secure in accordance with our internal procedures covering the storage, disclosure of and access to Personal Information. Personal Information may be kept on our Information Technology systems, those of our contractors or in paper files.

For Personal Information subject to the General Data Protection Regulation (EU) 2016/679 (“GDPR”) we may transfer your Personal Information outside the EEA for the Permitted Purposes as described above. This may include countries that do not provide the same level of protection as the laws of your home country (for example, the laws within the EEA or the United States). We will ensure that any such international transfers are made subject to appropriate or suitable safeguards if required by the GDPR or other relevant laws. You may contact us at any time using the contact details below if you would like further information on such safeguards.

With respect to persons covered by GDPR, in case Personal Information is transferred to countries or territories outside of the European Economic Area (“EEA”) that are not recognized by the European Commission as offering an adequate level of data protection, we have put in place appropriate data transfer mechanisms to ensure Personal Information is protected.

If any of the Personal Information that you have provided to us changes, for example if you change your email address or if you wish to cancel any request that you have made of us, please let us know by contacting EMF Customer Service through the EMF website at www.maritimefinance/contact-us/. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete Personal Information that you provide to us.

We retain your Personal Information in an identifiable form in accordance with our internal policies which establish general standards and procedures regarding the retention, handling and disposition of your Personal Information. Personal Information is retained for as long as necessary to meet legal, regulatory and business requirements. Retention periods may be extended if we are required to preserve your Personal Information in connection with litigation, investigations and proceedings.

With respect to EEA residents and where your Personal Information is processed by an European Maritime Finance Entity established in the EEA (“Covered Individuals”).

If you are a Covered Individual, you have a number of legal rights under GDPR in relation to the Personal Information that we hold about you. These rights include:

Obtaining information regarding the processing of your personal information and access to the personal information that we hold about you. Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information, (in particular, information that is subject to legal professional privilege);

Requesting that we correct your personal information if it is inaccurate or incomplete;

Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled to retain it;

Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request;

Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so.

We have designated a Data Protection Officer (“DPO”) to enhance and promote compliance with and understanding of privacy and data protection principles. If you wish to do any of the above, please send an email to info@maritimefinance.dk.

We may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorized disclosure of data. We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your data and for any additional copies of the Personal Information you request from us.

We will consider any requests or complaints that we receive and provide you with a response in a timely manner. If you are not satisfied with our response, you may take your complaint to the relevant privacy regulator. We will provide you with details of your relevant regulator upon request.

This Privacy Policy was last updated on 22 May 2018. We reserve the right to update and change this Privacy Policy from time to time, for example, in order to reflect any changes to the way in which we process your Personal Information or changing legal requirements. In case of any such changes, we will post the changed Privacy Policy on our website or publish it otherwise. The changes will take effect as soon as they are posted on our website.

We welcome your views about our website and our Privacy Policy. If you have any questions about this Policy, please contact the Data Protection Office or please contact EMF.