Privacy Policy for KCM Trade App

Effective Date: 01 October 25

KCM Trade is owned and operated by Kohle Capital Markets Limited ("we," "us," or "our"). Protecting your privacy is critical to us, and we are committed to handling your personal data responsibly and transparently. This Privacy Policy outlines how we collect, use, disclose, and protect your information.

By downloading, accessing, or using our App, you acknowledge that you have read and understood this Privacy Policy and agree to its terms. If you do not agree, you must refrain from using the App.

1. About Us

The services provided on this App are operated by:

• Kohle Capital Markets Limited, a part of the KCM Group, regulated by the Mauritius Financial Services Commission (FSC) (Regulatory Number: C117022600).
• Address: The Cyberati Lounge, Ground Floor, The Catalyst, Silicon Avenue, 40 Cybercity, Ebene 72201, Republic of Mauritius.
• Parent Company: KCM Group Holdings Limited.
• Website: https://www.kcmtrade.com/
• Contact Email: cs@kcmtrade.com

2. Legal Age for Use

The App is not intended for use by individuals under the age of 17. By using the App, you confirm that you are at least 17 years old. We reserve the right to terminate accounts or restrict access for users who provide false age information.

3. Information We Collect

We collect information in accordance with applicable laws and regulations. The types of data we collect include:

a. Personal Information

Name, contact details (email, phone number), and other details provided during registration. Location information based on device settings, such as GPS or IP-based geolocation.

b. Usage and Interaction Data

Interaction with App features, pages visited, and preferences, collected via:

• Matomo Analytics
• Firebase Analytics
• Google Analytics

c. Crash Logs and Diagnostics

Collected using Firebase Crashlytics to monitor and improve App performance.

d. Advertising Data

Data on interactions with ads and campaigns to provide personalized marketing and measure effectiveness.

e. Other Data

Any additional data collected via surveys, forms, or feedback submitted through the App.

4. How We Use Your Information

Your data is used for the following purposes:

1. Provision of Services: Ensuring the App's functionality and delivering core services.
2. Enhancing User Experience: Personalizing content, features, and recommendations.
3. Analytics and Improvements: Understanding user behavior to improve App performance and usability.
4. Compliance: Meeting legal, regulatory, and reporting obligations.
5. Advertising and Marketing: Displaying tailored advertisements based on user preferences and behavior.

5. Data Sharing and Transfers

We do not sell or rent your personal data. Data sharing is limited to:

1. Service Providers: To support analytics, advertising, payment processing, and diagnostics.
2. Regulatory Authorities: When required to comply with legal or regulatory obligations.
3. Affiliated Entities: To facilitate business operations within the KCM Group.
4. Third Parties in Legal Contexts: For dispute resolution, fraud prevention, or to protect company rights.

International data transfers may occur, and we ensure such transfers comply with applicable data protection laws.

6. Your Rights

You have the following rights concerning your personal data, subject to applicable laws:

1. Access and Portability: Request access to data we hold about you.
2. Correction: Request updates or corrections to inaccurate data.
3. Deletion: Request deletion of your data, except where retention is required by law.
4. Restrict Processing: Object to or restrict certain uses of your data.
5. Withdraw Consent: Opt-out of marketing or analytics via App or device settings.

To exercise these rights, contact us at cs@kcmtrade.com.

7. Data Retention

We retain your data for as long as needed to fulfill the purposes outlined in this Privacy Policy or as required by law. When no longer necessary, data will be securely deleted.

8. Security Measures

We implement industry-standard security measures, including encryption, secure servers, and access controls. However, no system is entirely immune to breaches. By using the App, you acknowledge and accept the inherent risks associated with data transmission and storage.

9. Cookies and Tracking

The App uses cookies and similar technologies for:

• Enhancing user experience.
• Enabling analytics and advertising.

You can control cookies through your device or browser settings.

10. Limitation of Liability

Kohle Capital Markets Limited is not liable for:

1. User Actions: Damages arising from unauthorized access to your account or misuse of the App.
2. Third-Party Services: Issues or damages caused by third-party platforms, tools, or services integrated into the App.
3. Force Majeure Events: Failures or interruptions caused by events beyond our control, including technical failures, natural disasters, or regulatory restrictions.

By using the App, you agree to indemnify and hold Kohle Capital Markets Limited harmless against claims, damages, or liabilities resulting from your use of the App.

11. Regulatory Compliance

Kohle Capital Markets Limited complies with applicable data protection laws, including:

• General Data Protection Regulation (GDPR) (where applicable).
• California Consumer Privacy Act (CCPA) (for U.S. users, where applicable).
• Mauritius Data Protection Act.

12. Dispute Resolution and Governing Law

All disputes arising from the use of this App or this Privacy Policy will be governed by the laws of Mauritius. Users agree to submit to the jurisdiction of courts in Mauritius for the resolution of disputes.

13. Changes to this Privacy Policy

We reserve the right to amend this Privacy Policy at any time. Changes will be effective upon posting the updated policy in the App. We encourage users to review the policy periodically.

14. Additional Terms

This Privacy Policy for the KCM Trade App supplements and is subject to the broader Privacy Policy available on our website. By using the App, you agree to the terms set forth here as well as those outlined in the full Privacy Policy of Kohle Capital Markets Limited, which can be accessed at:
https://www.kcmtrade.com/documents/privacy-policy.

In the event of any inconsistency between this App Privacy Policy and the Website Privacy Policy, the terms of the Website Privacy Policy will apply to the extent permitted by applicable law.

15. Contact Us

If you have questions or concerns about this Privacy Policy, contact us at:

• Email: cs@kcmtrade.com
• Website: https://www.kcmtrade.com/

Kohle Capital Markets Limited is committed to compliance, transparency, and safeguarding your privacy. By using the App, you accept and agree to these terms.