PRIVACY NOTICE STATEMENT

STATEMENT
This Statement explains how personal data relating to you will be handled by Fares.Fund (“Fares.Fund”, “we” or “us”) and sets out how and why your personal data will be collected and processed by Fares.Fund and/or on its behalf by its third-party service providers. For the purpose of this Statement, Fares.Fund is the controller of your personal data. This Statement is effective from the January 1, 2019 and remains effective until a more recent version is released. Fares.Fund reserves the right to amend or supplement this Document at any time, as explained below in this Statement.

APPLICATION OF THIS STATEMENT
This Statement applies to the way we collect and process your personal data. Personal data will be collected and processed by Fares.Fund when you avail of our services, whether through Fares.Fund (our “Websites”) or otherwise.
We will collect, use, disclose, transfer and store personal data when needed to provide our services and for our operational and business purposes as described in this Statement.

DEFINITIONS
For the purposes of this Privacy Notice, the following definitions as provided by the General Data Protection Regulation (GDPR) shall apply:
Data controller – the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Personal data – any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Data subject – any living individual who is the subject of personal data held by an organisation.
Processing – any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

DATA CONTROLLER
In line with the definition above, Fares.Fund shall be considered data controller under GDPR.

DATA PROTECTION OFFICER
1. DESCRIPTION

The Data Protection Officer (DPO) has been designated by Fares.Fund’s Board of Directors for the management of personal data within Fares.Fund and for ensuring the compliance with data protection legislation under the DPA, EU GDPR and any other data protection legislation and good practice can be demonstrated.

2. RESPONSIBILITIES

•The Data Protection Officer (DPO) is responsible for ensuring that this notice is made available to data subjects prior to Fares.Fund collecting/processing their personal data.
•DPO is responsible for the development, maintenance, and implementation of Fares.Fund’s data protection policy, as well as training of the Employees.
•DPO is also the main point of contact for data subjects and Employees with respect to subject access requests, including data rectification and erasure. DPO is also responsible for the handling of complaints as related to personal data.
•All employees of Fares.Fund who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.

PERSONAL DATA WE PROCESS
Device information When using our Website(s) we collect information about your computer/device browser including your IP address accessed pages within the internet presence, date and time of the visit, cookies, used browser, operating system of the accessing computer, language setting and transferred data volume. Please see our Cookie Policy for further information. The processing of the device information is done mainly in order to establish the connection, to ensure system security and for reasons of technical administration.
•Such information is transmitted automatically by your internet browser is exclusively stored and analysed statistically in an anonymous form, in order to continuously improve this internet presence, to adjust it to the users’ interests and to speed up the detection and/or elimination or bugs.
Also, device information is exclusively stored and analysed statistically in an anonymous form, in order to continuously improve this internet presence, to adjust it to the users’ interests and to speed up the detection and/or elimination or bugs.
Transactions Information about the anticipated and actual volume and value of your transactions with us, payment methods information provided in order to enable the construction of your economic profile.

c. Personal Information As part of the registration with Fares.Fund we collect personal information which may include, amongst others, your name, date of birth, residential address, email address, telephone number, occupation, financial information and statements including details about your income and assets, copies of government issued identification including your passport or Identification Card (which contain a photo of you) or similar identifying information. Such information is requested to be disclosed in order to enable us to evaluate your application and comply with relevant rules and regulations. When an application is submitted, we are required by law to verify the client’s identity as well as the rest of the information provided and conduct appropriate research against any possible fraud/money laundering/crime issues and risks.

d. Other Information We may also process any personal data which you choose to provide us. In addition, we may receive information about you, including but not limited any negative media or publication about you, your affiliation with certain companies or activities, involvement in illegal activities or inclusion in sanctions lists from our trusted third party service providers. Such information is necessary for us to comply with our obligations under the laws on prevention of money laundering and prevention of terrorism financing.

HOW AND WHY WE PROCESS YOUR PERSONAL DATA
The following table shows our legal basis for the processing of personal data and the purposes of collection and processing as well as any legitimate interests pursued by us:
LEGAL BASIS PURPOSE(S)

CONTRACT

It is necessary to process your personal data to enter into and perform our terms of use (the “Agreement”) with you for the provision of our services

We obtain, collect and process your personal data:
•To set up an account with us, provide technical and customer support and training, process payment information. This information is required for the purposes of Fares.Fund performing its obligations under the terms of the Agreement and for the purposes of complying with the laws and regulations applicable to us.
•To verify your identity, age and accuracy of your registration details
•For marketing purposes (with the right to opt out)
•For marketing research to improve our services
•To enable us to fulfill our contractual obligations owed to you (establish bank accounts for the purposes of safeguarding clients’ funds; suitability assessment to allow purchasing of financial interests etc)

LEGITIMATE INTERESTS
We process certain personal data on the basis of our legitimate interests, such as pursuit of or business or security interests. Where we process your personal data in pursuit of our legitimate interests we determine if such processing is necessary and we carefully consider the impact of our processing activities on your fundamental rights and freedoms. We will not process your personal data where our legitimate interests are outweighed by the impact on your rights and freedoms (unless otherwise required or permitted by law).
You are entitled to object to us processing your personal data on the basis of our legitimate interests. For more on this and other rights please see section on "Your Right under the GDPR”

We obtain, collect and process your personal data in order to:
•Provide you with access to our Website(s) and to enable you to use them;
•Provide you with information about our products and services;
•Respond to your enquiries;

Compliance with legal and regulatory obligation.
We may be required to collect, use and/or retain personal data for legal and compliance reasons such as compliance with Anti-Money Laundering obligations under the European legislation framework.

DISCLOSURE OF PERSONAL DATA
To verify your account and identity we may disclose such information to third parties such as financial institutions, third party reference agencies and data verification service providers to comply with our legal obligations.

We will also disclose your personal information to other third parties including:
•regulatory authorities and law enforcement agencies;
•non-affiliated third parties for payments processing, payments, sales, data analysis, research and surveys; and/or
•professional advisors such as tax or legal advisors, consultants and accountants.

TRANSFERS OF YOUR OF PERSONAL DATA
In servicing your account, we may transfer your information to our third- party agents or service providers (including those who are involved in the operation, service, administration or management of Fares.Fund) in countries in or outside the EEA (European Economic Area). We use our best efforts to ensure that those third-party agents and service providers provide the same level of protection the Privacy Policy requires and limit their use of the data to the specified services provided on our behalf. We may, however, use providers from third countries where the level of personal data protection is lower than that of the EEA. We take reasonable and appropriate steps to ensure that third-party agents and service providers process your personal data in accordance with our Privacy Policy obligations and to stop and remediate any unauthorized processing.

If you would like to find out more about the appropriate safeguards that we have in place to govern the transfer of your personal data, you can contact us at [email protected]

By using our services and agreeing to this Privacy Notice, you confirm that you agree with the transfer and processing of your data to third parties, including those outside the EEA. You may withdraw your consent at any time by completing the Withdrawal of Consent Form.

YOUR RIGHTS UNDER THE GDPR
At any point while we are in possession or of processing your personal data, you the data subject, have the following rights:
•The right of access- you have the right to request a copy of the information that we hold about you.
•The right of rectification- you have a right to correct data that we hold about you that is inaccurate or incomplete.
•The right to be forgotten- in certain circumstances you can ask for the data we hold about you to be erased from our records where there is no compelling reason to continue processing. This right only applies in certain circumstances and it is not guaranteed or absolute as we are obliged to retain your data in accordance with clause 9 below.
•The right to restriction of processing of your personal.
•The right of data portability. You have the right to have the data we hold about you transferred to another service or organisation.
•The right to object to automated processing, including profiling- you also have the right to be subject to the legal effects of automated processing or profiling.
•The right to object to us using your personal data for a particular purpose or purposes. You may contact Fares.Fund’s Data Protection Officer at any time at [email protected]
to exercise your rights as a data subject.

CONSENT
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Your continued use of service indicates ongoing consent to the Privacy Policy.

Consent is required for Fares.Fund to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw your consent at any time by completing the Withdrawal of Consent Form and sending it to the Data Protection Officer to [email protected]

RETENTION OF YOUR PERSONAL DATA
Fares.Fund will process the information you provide in a manner compatible with the EU’s GDPR. We will endeavor to keep your information accurate and up to date, and not keep it for longer than necessary. Generally, we shall retain your personal data for a period of five (5) years in order for us to comply with our anti-money laundering obligations under the European regulatory framework.

COMPLAINTS
In the event that you wish to make a complaint about your personal data is being processed by Fares.Fund (or third parties) or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Fares.Fund’s data protection representatives; the Data Protection Officer. The Contact details of the DPO are provided below: [email protected]
Should you feel that the complaint is not resolved to your satisfaction, you can direct your complaint to the Data protection Authority in your jurisdiction.

CHANGES TO OUR PRIVACY NOTICE STATEMENT
We may occasionally update this Statement to reflect changes in our business or to comply with applicable law and regulations. If there are material changes to this Statement concerning how we use your personal data, we will notify you by prominently posting a statement of such changes on the relevant Website before they take effect.

COOKIES POLICY

This policy was last updated on December 9, 2020. Please print a copy of these Terms and Conditions for your reference.

INTRODUCTION
The Fares.Fund website (the “Websites”) is operated by Fares.Fund (“Fares.Fund”, “we” or “us”).

This is our Cookie Policy on the use of cookies on our Websites which we may update from time to time to reflect changes in our business or to comply with applicable law and regulations. You should check this page to ensure you understand any changes made.

WHAT ARE COOKIES AND HOW WE USE THEM

A cookie is a small data file that is stored on your computer.
The types of cookies we use

•Necessary
These are cookies that are absolutely necessary for the operation and use of our Websites. Disabling these cookies will cause the Websites to not function properly and essential security features cannot be activated.
•Performance
Some cookies are used to count the visitors to our Websites and to see how visitors use our Websites in order to improve performance of our Websites and ensure effective web navigation. These cookies do not collect information which is personally identifiable but such information is rather gathered anonymously.

You can disable/delete this type of cookies, but this may cause for some features of the Website to not work properly or as intended.

•Functionality
The Websites store cookies to allow the Website to remember information such user ID information, passwords and viewing preferences, thus allowing You to visit member-only areas of the Website without logging in again. Cookies which use your user ID information and passwords will only be use if you have provided your consent
•Tracking cookies
These cookies are used for the purpose of tracking a user’s visit to a website, the individual pages visited, and the links followed. This information is collected anonymously to understand the users’ general online behaviour and further understand how our online advertising is working. We do not use this information to serve you personalized advertising.
•Google Analytics HOW TO CONTROL COOKIES
You can set your web browser to inform you when cookies are enabled, or to disable cookies. If you do not wish to receive cookies, web browsers will permit you to disable and/or www.aboutcookies.org delete cookies, for further details please visit

Please be aware that if you delete or disable cookies, some of the Websites’ functionalities may be lost.

For more information on how to manage cookies, please visit
http://ec.europa.eu/ipg/basics/legal/cookies/index_en.htm

CONTACT US
If you have any queries in relation to this cookies policy, please contact us at any form on website or by mail [email protected]

PRIVACY NOTICE

STATEMENT
This Statement explains how personal data relating to you will be handled by Fares.Fund (“Fares.Fund”, “we” or “us”) and sets out how and why your personal data will be collected and processed by Fares.Fund and/or on its behalf by its third-party service providers. For the purpose of this Statement, Fares.Fund is the controller of your personal data.
This Statement is effective from the 9nd of December, 2020 and remains effective until a more recent version is released. Fares.Fund reserves the right to amend or supplement this Document at any time, as explained below in this Statement.

APPLICATION OF THIS STATEMENT
This Statement applies to the way we collect and process your personal data. Personal data will be collected and processed by Fares.Fund when you avail of our services, whether through Fares.Fund or Fares.Fundplatform.com (our “Websites”) or otherwise.
We will collect, use, disclose, transfer and store personal data when needed to provide our services and for our operational and business purposes as described in this Statement.

DEFINITIONS
For the purposes of this Privacy Notice, the following definitions as provided by the General Data Protection Regulation (GDPR) shall apply:
Data controller – the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Personal data – any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Data subject – any living individual who is the subject of personal data held by an organisation.
Processing – any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

DATA CONTROLLER
In line with the definition above, Fares.Fund shall be considered data controller under GDPR.

DATA PROTECTION OFFICER
1. DESCRIPTION

The Data Protection Officer (DPO) has been designated by Fares.Fund’s Board of Directors for the management of personal data within Fares.Fund and for ensuring the compliance with data protection legislation under the DPA, EU GDPR and any other data protection legislation and good practice can be demonstrated.

2. RESPONSIBILITIES

•The Data Protection Officer (DPO) is responsible for ensuring that this notice is made available to data subjects prior to Fares.Fund collecting/processing their personal data.
•DPO is responsible for the development, maintenance, and implementation of Fares.Fund’s data protection policy, as well as training of the Employees.
•DPO is also the main point of contact for data subjects and Employees with respect to subject access requests, including data rectification and erasure. DPO is also responsible for the handling of complaints as related to personal data.
•All employees of Fares.Fund who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.
PERSONAL DATA WE PROCESS
Device information
When using our Website(s) we collect information about your computer/device browser including your IP address accessed pages within the internet presence, date and time of the visit, cookies, used browser, operating system of the accessing computer, language setting and transferred data volume. Please see our Cookie Policy for further information. The processing of the device information is done mainly in order to establish the connection, to ensure system security and for reasons of technical administration. Such information is transmitted automatically by your internet browser is exclusively stored and analysed statistically in an anonymous form, in order to continuously improve this internet presence, to adjust it to the users’ interests and to speed up the detection and/or elimination or bugs.
Also, device information is exclusively stored and analysed statistically in an anonymous form, in order to continuously improve this internet presence, to adjust it to the users’ interests and to speed up the detection and/or elimination or bugs.

Transactions Information about the anticipated and actual volume and value of your transactions with us, payment methods information provided in order to enable the construction of your economic profile.

c. Personal Information

As part of the registration with Fares.Fund we collect personal information which may include, amongst others, your name, date of birth, residential address, email address, telephone number, occupation, financial information and statements including details about your income and assets, copies of government issued identification including your passport or Identification Card (which contain a photo of you) or similar identifying information. Such information is requested to be disclosed in order to enable us to evaluate your application and comply with relevant rules and regulations. When an application is submitted, we are required by law to verify the client’s identity as well as the rest of the information provided and conduct appropriate research against any possible fraud/money laundering/crime issues and risks.

d. Other Information

We may also process any personal data which you choose to provide us. In addition, we may receive information about you, including but not limited any negative media or publication about you, your affiliation with certain companies or activities, involvement in illegal activities or inclusion in sanctions lists from our trusted third party service providers. Such information is necessary for us to comply with our obligations under the laws on prevention of money laundering and prevention of terrorism financing.

HOW AND WHY WE PROCESS YOUR PERSONAL DATA
The following table shows our legal basis for the processing of personal data and the purposes of collection and processing as well as any legitimate interests pursued by us:
LEGAL BASIS PURPOSE(S)

CONTRACT

It is necessary to process your personal data to enter into and perform our terms of use (the “Agreement”) with you for the provision of our services
We obtain, collect and process your personal data:

•To set up an account with us, provide technical and customer support and training, process payment information. This information is required for the purposes of Fares.Fund performing its obligations under the terms of the Agreement and for the purposes of complying with the laws and regulations applicable to us.
•To verify your identity, age and accuracy of your registration details
•for marketing purposes (with the right to opt out)
•for marketing research to improve our services
•to enable us to fulfill our contractual
obligations owed to you (establish bank accounts for the purposes of safeguarding clients’ funds; suitability assessment to allow purchasing of financial interests etc)

LEGITIMATE INTERESTS We process certain personal data on the basis of our legitimate interests, such as pursuit of or business or security interests. Where we process your personal data in pursuit of our legitimate interests we determine if such processing is necessary and we carefully consider the impact of our processing activities on your fundamental rights and freedoms. We will not process your personal data where our legitimate interests are outweighed by the impact on your rights and freedoms (unless otherwise required or permitted by law).
You are entitled to object to us processing your personal data on the basis of our legitimate interests. For more on this and other rights please see section on "Your Right under the GDPR”

We obtain, collect and process your personal data in order to:

•Provide you with access to our Website(s) and to enable you to use them;
•Provide you with information about our products and services;
•Respond to your enquiries;

Compliance with legal and regulatory obligation.
We may be required to collect, use and/or retain personal data for legal and compliance reasons such as compliance with Anti-Money Laundering obligations under the European legislation framework.

DISCLOSURE OF PERSONAL DATA
To verify your account and identity we may disclose such information to third parties such as financial institutions, third party reference agencies and data verification service providers to comply with our legal obligations.

We will also disclose your personal information to other third parties including:

•regulatory authorities and law enforcement agencies;
•non-affiliated third parties for payments processing, payments, sales, data analysis, research and surveys; and/or
•professional advisors such as tax or legal advisors, consultants and accountants.

TRANSFERS OF YOUR OF PERSONAL DATA
In servicing your account, we may transfer your information to our third- party agents or service providers (including those who are involved in the operation, service, administration or management of Fares.Fund) in countries in or outside the EEA (European Economic Area). We use our best efforts to ensure that those third-party agents and service providers provide the same level of protection the Privacy Policy requires and limit their use of the data to the specified services provided on our behalf. We may, however, use providers from third countries where the level of personal data protection is lower than that of the EEA. We take reasonable and appropriate steps to ensure that third-party agents and service providers process your personal data in accordance with our Privacy Policy obligations and to stop and remediate any unauthorized processing.

If you would like to find out more about the appropriate safeguards that we have in place to govern the transfer of your personal data, you can contact us at [email protected]

By using our services and agreeing to this Privacy Notice, you confirm that you agree with the transfer and processing of your data to third parties, including those outside the EEA. You may withdraw your consent at any time by completing the Withdrawal of Consent Form.

YOUR RIGHTS UNDER THE GDPR
At any point while we are in possession or of processing your personal data, you the data subject, have the following rights:

•The right of access- you have the right to request a copy of the information that we hold about you.
•The right of rectification- you have a right to correct data that we hold about you that is inaccurate or incomplete.
•The right to be forgotten- in certain circumstances you can ask for the data we hold about you to be erased from our records where there is no compelling reason to continue processing. This right only applies in certain circumstances and it is not guaranteed or absolute as we are obliged to retain your data in accordance with clause 9 below.
•The right to restriction of processing of your personal.
•The right of data portability. You have the right to have the data we hold about you transferred to another service or organisation.
•The right to object to automated processing, including profiling- you also have the right to be subject to the legal effects of automated processing or profiling.
•The right to object to us using your personal data for a particular purpose or purposes.
You may contact Fares.Fund’s Data Protection Officer at any time at [email protected]
to exercise your rights as a data subject.

CONSENT
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Your continued use of service indicates ongoing consent to the Privacy Policy.

Consent is required for Fares.Fund to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw your consent at any time by completing the Withdrawal of Consent Form and sending it to the Data Protection Officer to [email protected]

RETENTION OF YOUR PERSONAL DATA
Fares.Fund will process the information you provide in a manner compatible with the EU’s GDPR. We will endeavor to keep your information accurate and up to date, and not keep it for longer than necessary. Generally, we shall retain your personal data for a period of five (5) years in order for us to comply with our anti-money laundering obligations under the European regulatory framework.

COMPLAINTS
In the event that you wish to make a complaint about your personal data is being processed by Fares.Fund (or third parties) or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Fares.Fund’s data protection representatives; the Data Protection Officer.
The Contact details of the DPO are provided below: [email protected]
Should you feel that the complaint is not resolved to your satisfaction, you can direct your complaint to the Data protection Authority in your jurisdiction.

CHANGES TO OUR PRIVACY NOTICE STATEMENT
We may occasionally update this Statement to reflect changes in our business or to comply with applicable law and regulations. If there are material changes to this Statement concerning how we use your personal data, we will notify you by prominently posting a statement of such changes on the relevant Website before they take effect.

CONTACT
If you have any concerns about the way your personal data are being used or processed by Fares.Fund, please contact us at [email protected]

© 2020 Fares.Fund CORPORATION. ALL RIGHTS RESERVED.