STOCKITY PRIVACY POLICY

INTRODUCTION

This Privacy Policy explains in detail how Verte Securities Limited (“the Company,” “We,” “Us,” or “Our”) collects, processes, stores, shares, and safeguards Your personal information when You access or use the Stockity Trading Platform. This includes the official website stockity.com (“the Website”), the Stockity Mobile Application, as well as any related online tools and services We provide. For all purposes described in this document, references to the Website and Stockity Mobile Application shall be treated as equivalent.

We are committed to protecting the confidentiality and integrity of the data of every individual using Our services (“user,” “You”). This document outlines how We obtain information from You, how We use it, under what circumstances it may be disclosed, and the steps We take to ensure its security across our Website, Stockity Mobile Application, and any additional digital interfaces We operate (“the Services”).

This Privacy Policy forms an essential and legally enforceable component of the Stockity Client Agreement. It applies to all individuals who register an Account or otherwise use Our Services, regardless of their country of residence. By creating an Account, accessing the Website or the Mobile Application, or using any part of Our Services, You confirm that You have read, understood, and unconditionally accepted every provision within this Privacy Policy.

Your personal data is collected and processed by Verte Securities Limited, a corporation legally registered in the Republic of Vanuatu (Company No. 700726), with its official registered address at Level 1, ICount House, Kumul Highway, Port Vila, Vanuatu. The Company acts as the data controller and is responsible for ensuring that Your personal information is processed in full compliance with applicable data protection laws.

We value Your trust and implement comprehensive technical, organizational, and legal safeguards to prevent unauthorized access, misuse, modification, or destruction of Your data. We encourage You to carefully review this Policy before using any of Our Services. If You disagree with any part of this document, You should cease using the Stockity Trading Platform. Continued use of Our Services signifies Your consent to the practices described herein.

Any terms not defined within this Privacy Policy shall be interpreted according to the definitions provided in the Stockity Client Agreement.

1. INFORMATION YOU PROVIDE TO US

1.1. Data Provided During Registration

When You register an Account on the Website or log in via the Stockity Mobile Application, You must supply a valid and active email address. After registration, You may voluntarily expand Your profile with additional details, such as Your full name, date of birth, gender, phone number, and country of residence. This information enables Us to personalize Your experience, verify Your identity, and ensure secure access to the Stockity Trading Platform.

1.2. Payment and Identity Information

To deposit funds or access specific financial features, You must provide payment and identity-related data, which may include:

Full legal name
Bank card number
Expiry date and security code (CVV/CVC)
Card issuer information
Payment system type (Visa, MasterCard, etc.)
Passport or national ID number
Date of birth
Residential address
Email address
Phone number
Additional data depending on the payment method selected

This information is essential for processing payments, complying with anti-fraud protocols, and meeting legal obligations such as anti-money laundering (AML) and counter-terrorist financing (CTF) requirements.

Payment data may be transferred to authorized Payment Service Providers, who may act as processors or independent controllers depending on the transaction. These entities may request additional documents, such as scanned IDs, to validate Your transactions. All such partners operate under strict data protection standards.

1.3. Identity Verification & Compliance Procedures

To comply with AML, CTF, and Know Your Customer (KYC) regulations, You must complete identity verification, which requires submission of:

A clear copy of a valid identity document
Photographs of payment cards or digital wallet screenshots
A selfie holding the identity document and card
When legally required, additional documents may be requested:
Recent utility bill showing Your name and address
Bank reference letter
Bank statement
Documents proving the source of funds
Secondary identification documents

All submitted materials must be genuine, current, and verifiable. These procedures protect both You and the integrity of the Stockity Trading Platform.

1.4. Activity Data and User Interaction

We automatically collect operational and analytical data when You use the Stockity Trading Platform, including:

Login records and session duration
Registration date and account type
IP address and device characteristics
Browser version
Language settings and time zone
Trading actions and platform navigation
System error logs and performance metrics
Clickstream behavior and interaction patterns
Customer support communication history

This information helps ensure platform stability, detect fraudulent activity, improve performance, and comply with regulatory obligations.

1.4.1. Prize Distribution and Promotional Activities

If You participate in promotions or receive gifts, You may need to provide Your name, delivery address, and phone number. These details are used solely for fulfillment of marketing activities and may be shared with logistics partners when necessary.

1.4.2. Surveys and Feedback

We may request Your name and email address if You choose to participate in voluntary surveys or service evaluations.

1.4.3. Customer Support

When contacting Support, You may be asked to provide Your full name and email address. Communications may be recorded for security, quality assurance, and dispute resolution.

1.5. Cookies and Tracking Technologies

We use Cookies and similar technologies to enhance functionality and personalize Your experience.

Essential Cookies include:

Session identification cookies
Navigation and interface preference cookies
Technical cookies identifying the source of Your visit

1.5.1. Usage Data From Cookies

Collected automatically:

IP address
Device and operating system
Browser version
Time zone and language
Access timestamps
Referring sources
Disabling Cookies may result in reduced platform functionality.

2. LEGAL BASIS FOR PROCESSING YOUR DATA

2.1. Lawful Processing Grounds

We process Your personal data only when permitted by law, based on:
Performance of Agreement — necessary for fulfilling Our contractual obligations to You.
Consent — voluntarily given when accepting this Privacy Policy and the Stockity Client Agreement.
Legal Obligations — required for AML/CTF compliance, tax regulations, financial reporting, etc.
Legitimate Interests — such as fraud prevention, service improvement, and internal analysis.

2.2. Refusal to Provide Data

If You choose not to provide essential information or withdraw consent (where applicable), We may be unable to maintain Your Account or provide certain Services. In such cases, You will be informed accordingly.

3. DATA RETENTION

3.1. Retention Period

We retain Your information only as long as necessary for:

Fulfilling the purposes outlined in this Privacy Policy
Meeting legal and regulatory obligations
Enforcing agreements
Handling disputes or investigations
Maintaining business records
Protecting legitimate interests

Once retention is no longer required, Your information is securely deleted or anonymized. Where legally mandated, certain data may be stored longer and used only for specific purposes (e.g., legal claims, audits).

4. PURPOSES OF PROCESSING YOUR INFORMATION

4.1. The personal data We collect is primarily used to ensure the smooth operation of the Stockity Trading Platform, enhance the quality of Our current services, and develop new functionalities. The main purposes for which We process Your information include, but are not limited to:

(i) Delivering secure, reliable, and high-quality services on the Stockity Trading Platform, including supporting uninterrupted technical operations, monitoring system performance, detecting and resolving technical issues, and improving the overall stability and responsiveness of Our Services across all devices;

(ii) Enhancing the usability and efficiency of the Stockity Trading Platform by employing Cookies and similar technologies to track interface interactions, device types, IP addresses, session data, and language settings, enabling Us to present content in the most suitable format and language for Your region and device;

(iii) Retaining and utilizing information collected during Your initial and subsequent visits to the Website to maintain the continuity of Your interaction with the Platform, such as remembering login credentials, preselected preferences, and customized interface settings;

(iv) Using registration and identity verification details (including Your full name, middle name if applicable, gender, date of birth, nationality, and contact information) to confirm Your identity, ensure the accuracy of Your Personal Account, and provide services tailored to Your needs while complying with applicable regulations;

(v) Supporting secure and legally compliant transactions by verifying financial documentation, cross-checking registration information against payment methods, and monitoring for fraudulent or unlawful activity in accordance with international standards and internal compliance procedures;

(vi) Facilitating deposits and other financial operations by storing non-sensitive information (excluding card numbers, expiration dates, CVC/CVV codes, or confidential banking credentials) to simplify future interactions, including autofilling previously provided payment details where allowed;

(vii) Collecting and analyzing records of Your financial and operational activities on the Platform, including transaction histories, IP addresses, login timestamps, and device/browser details, to ensure fund security, detect and prevent fraud, and comply with anti-money laundering (AML) requirements;

(viii) Sending system-generated notifications regarding important operational matters (such as maintenance, Platform updates, or service modifications), and delivering personalized advertising or promotional messages via email, SMS, phone calls, and other legally permitted channels. You may manage or opt out of promotional communications at any time through Your Personal Account settings or by contacting Support;

(ix) Informing You about changes to Website operations, Service updates, amendments to this Privacy Policy or the Stockity Client Agreement, or new regulatory requirements. Such communications are considered essential and may not always be optional;

(x) Creating a personalized experience by tailoring Website content and marketing campaigns based on Your activity, preferences, behavioral patterns, and device data, allowing Us to present more relevant offers and improve Your satisfaction with Our Services;

(xi) Responding efficiently to Your support requests, questions, or complaints by collecting, storing, and reviewing communication records and relevant data to ensure proper documentation and timely resolution.

4.2. Should We wish to use Your personal data for purposes not explicitly described above, We will first obtain Your explicit and informed consent. Additionally, any automated processing of personal data will not result in decisions that produce legal effects or similarly significant impacts on You, unless appropriate safeguards are implemented.

5. DISCLOSURE OF YOUR INFORMATION

5.1. We will only disclose Your personal data when it is necessary and strictly in line with this Privacy Policy and applicable laws. Such disclosure may occur in the following situations:

Business Transactions: In the event of a corporate transaction, such as a merger, acquisition, restructuring, or sale of assets, Your personal data may be shared or transferred to the relevant third party as part of the transaction. We will take reasonable measures to ensure that the receiving party upholds data protection standards consistent with this Privacy Policy. You will be notified if Your data becomes subject to a different privacy policy prior to the transfer.

Legal Requirements and Law Enforcement: We may disclose Your personal data if required by law or in response to lawful requests from governmental authorities, courts, regulatory agencies, or law enforcement bodies. This includes obligations under anti-money laundering (AML), financial crime prevention, or counter-terrorism financing (CTF) regulations.

Protection of Legal Rights and Safety: We may share personal data when, in Our reasonable judgment and good faith, it is necessary to:

(i) Comply with a legal obligation or enforce applicable laws and regulations;

(ii) Protect and defend the legal rights, property, or interests of the Company, Our users, or affiliates;

(iii) Detect, prevent, or investigate suspected violations of the Stockity Client Agreement or other unlawful conduct;

(iv) Safeguard the personal safety and interests of Our clients, employees, or the public;

(v) Avoid legal liability or respond to claims or disputes against the Company.

5.2. We require that any third party receiving Your personal data is legally obligated to maintain confidentiality and handle the data in strict accordance with applicable data protection and privacy law

6. TRANSFER OF YOUR INFORMATION

6.1. Due to the international scope of Our operations and service infrastructure, Your personal data may be transferred to, stored, and processed in countries other than Your country of residence. These countries may not provide the same level of data protection as those in Your home jurisdiction.

6.2. By accepting this Privacy Policy and providing Your personal data via the Website or Stockity Mobile Application, You expressly consent to such cross-border transfers. These transfers are carried out solely as necessary to fulfill the Stockity Client Agreement, deliver Our Services, or as otherwise permitted by applicable law.

6.3. We implement all reasonable measures to ensure that any transfer of Your personal data outside Your jurisdiction is conducted with adequate safeguards. Such measures may include:

Establishing contractual agreements with recipients of Your data, incorporating standard data protection clauses approved by regulatory authorities;
Ensuring that third-party service providers (including cloud storage and customer support providers) comply with strong data protection standards;
Requiring third parties to maintain appropriate technical and organizational safeguards to protect Your data against unauthorized access, use, or disclosure.

6.4. Personal data will only be transferred once We are satisfied that sufficient protections are in place to secure Your information, preserve confidentiality, and ensure lawful processing in accordance with this Privacy Policy and applicable legislation.

7. YOUR RIGHTS REGARDING YOUR INFORMATION

7.1. We respect Your rights under applicable data protection laws and strive to facilitate their exercise transparently and efficiently. Subject to legal or contractual limitations, You have the following primary rights concerning Your personal data:

Right of Access: You may request confirmation of whether We process Your personal data and, if so, obtain a copy of the data along with details of how it is processed.
Right to Rectification: You may request corrections to or completion of any inaccurate or incomplete personal data We hold about You. We may verify the accuracy of any new information before updating our records.
Right to Erasure (“Right to be Forgotten”): You may request the deletion of Your personal data when no valid legal basis exists for its continued processing. This right is subject to the conditions set forth in applicable laws.
Right to Restriction or Objection: You may request restrictions on the processing of Your personal data or object to certain types of processing (e.g., direct marketing or profiling based on legitimate interests) in specific circumstances.
Right to Withdraw Consent: Where processing is based on Your consent, You may withdraw it at any time. Withdrawal does not affect the lawfulness of processing conducted before consent was withdrawn.

7.2. These rights are not absolute and may be limited by applicable laws, particularly in relation to anti-money laundering (AML), know-your-customer (KYC), financial reporting, or other legal obligations. In some cases, exercising certain rights (such as erasure or restriction) may prevent Us from providing Services or may require the termination of Our contractual relationship.

8.1. We do not share or transfer Your personal data to any third parties unrelated to Your use of the Stockity Trading Platform, except when necessary to fulfill Our contractual or legal obligations, provide You with Our services, or support Our legitimate business interests in line with this Privacy Policy.

8.2. Any third parties receiving Your data act strictly on Our behalf and follow Our explicit instructions. These parties are contractually required to maintain the confidentiality and security of Your information. They may include:

Selected employees of the Company or its affiliates who need access to personal data to perform their duties;
Independent professional auditors for regulatory or compliance audits;
Dispute resolution entities or arbitrators handling claims or complaints;
Financial institutions and payment systems processing Your transactions;
Payment service providers assisting with deposits, withdrawals, or other financial operations;
Identity verification and KYC providers to comply with AML/CTF regulations;
IT and infrastructure providers critical for the functionality and reliability of the Stockity Trading Platform.

8.3. For identity verification and transaction checks, We use Sum and Substance Limited (UK Registration No. 09688671), which may access personal data You provide during verification. More information is available in their Privacy Policy: https://sumsub.com/privacy-notice/

8.4. We may share aggregated, anonymized, or statistical data with analytics and marketing partners that does not directly identify You. Examples include:

Google Analytics: Tracks user interactions on the Platform to improve performance and personalize advertising. https://policies.google.com/privacy
Cloudflare: Provides network security and hosting services, with data stored in the EU and US. https://www.cloudflare.com/privacypolicy/
Zendesk: Manages communications with Our support team. Data You provide when contacting Support may be accessed by Zendesk. https://www.zendesk.com/company/agreements-and-terms/privacy-policy/

8.5. For promotional campaigns, rewards, or branded gifts, We may share Your name, address, and phone number with authorized courier services or marketing partners solely to deliver these items.

8.6. In the event of a merger, acquisition, or corporate restructuring, Your personal data may be transferred to the new entity, provided it commits to protecting Your data according to this Privacy Policy.

8.7. We may transfer Your data to countries outside the European Economic Area (EEA). In such cases, We ensure adequate safeguards (e.g., contractual clauses, technical measures) to maintain protection levels comparable to those within the EEA.

8.8. Only with Your explicit consent may We share Your personal data with third parties not listed above, and solely for clearly defined purposes communicated at the time consent is requested.

9. PROTECTING TECHNICAL AND PERSONAL INFORMATION

9.1. We employ administrative, technical, and organizational safeguards to protect Your personal data and all other information transmitted or stored via the Stockity Trading Platform. These measures are designed to maintain confidentiality, prevent unauthorized access, and ensure system integrity.

9.2. Data transmitted between Your device and Our servers is protected using Secure Sockets Layer (SSL) encryption, ensuring that communications—such as login credentials, financial transactions, and personal data—remain secure and tamper-proof.

9.3. Despite Our use of industry-standard protections, no online transmission or storage method is entirely secure. We encourage You to exercise caution when sharing sensitive information and to use strong, unique passwords for Your Account.

10. PASSWORDS AND ACCOUNT SECURITY

10.1. When creating a Stockity Account, You must provide a valid email address and set a strong password, known only to You, to access Your Account. Passwords are never stored or visible to Us in plain text.

10.2. We cannot change Your password or email credentials. You are solely responsible for maintaining their confidentiality and for all activities conducted through Your Account.

10.3. We recommend that You:

Use a unique, complex password containing letters, numbers, and symbols;
Avoid reusing passwords across multiple platforms;
Update Your password regularly and immediately if You suspect a security breach.

10.4. If You notice unauthorized access or any suspicious activity (e.g., logins from unknown locations or unexpected profile changes), You must contact Our Support Service immediately. Prompt reporting allows Us to secure Your Account and investigate potential breaches.

11. USE OF OUR SERVICES BY MINORS

11.1. Our services, including access to the Website, Stockity Mobile Application, and all features of the Stockity Trading Platform, are intended solely for individuals who have reached the legal age of majority as defined by the laws of their jurisdiction. We do not knowingly collect, process, or store personal data from individuals below the minimum legal age required to enter binding agreements or access financial services.

11.2. If We become aware or reasonably suspect that a person under the legal age has attempted to register or submitted personal data through Our services, We will promptly delete such information from Our systems and terminate the related Account.

11.3. We encourage parents and legal guardians to monitor minors’ online activities and assist Us in enforcing this policy by reporting any suspected unauthorized access or registration of minors to Our Support Service.

11.4. By using the Stockity Trading Platform, You confirm and warrant that You are of legal age in accordance with the laws of Your jurisdiction and have full legal capacity to use Our services.

12. CHANGES TO THIS PRIVACY POLICY

12.1. We reserve the right to update, revise, or amend this Privacy Policy periodically to reflect changes in laws, regulations, Our practices, or service enhancements. Any updates will not limit or reduce Your legal rights under applicable data protection laws.

12.2. Material changes to this Privacy Policy will be published on the Website with the date of the latest revision clearly indicated. Unless stated otherwise, the updated version will take effect immediately upon publication. We may also notify You of significant changes via email or other reasonable communication methods.

12.3. Your continued use of the Website, Stockity Mobile Application, or Our Services after the updated Privacy Policy takes effect constitutes Your acknowledgment and acceptance of the revised terms. If You do not agree with the changes, You must stop using the Stockity Trading Platform and may close Your Account by withdrawing Your funds and contacting Our Support Service, as outlined in the Stockity Client Agreement.

12.4. In the event of any inconsistency between the English version of this Privacy Policy and its translations into other languages, the English version shall prevail for interpretation and legal purposes.

13. CONTACT INFORMATION

13.1. If You have any questions, concerns, or requests regarding the processing of Your personal data, or if You wish to exercise any of Your rights under this Privacy Policy—including withdrawing consent or verifying the data We hold about You—please contact Our designated Data Protection Team at: [email protected]