This Policy describes how the Apricot Capital application may collect, use and share information from or about you and explains how the information may be shared or used.

1. Agreement to Policy

By using the Apricot Capital application you consent to this Policy which includes your consent to disclose and use information about you in the manner detailed in this Policy.

2. Information that we collect

We collect the following personal data:

• Identity data includes full name or its parts, username or similar identifier, marital status, title, date and place of birth, nationality, tax number, gender, information from your identity document(s), employment status and related information, and your pictures/pictures of your identity (including biometric information such as a visual image of your face) or another document
(s) we may request from time to time.

• Contact data includes billing address, residential address, email address and telephone number.

• Screening data includes close connections, political background and information pertaining to sanctions and adverse media.

• Risk assessment data includes client risk score and client risk categorization.

• Economic and appropriateness data include employment status, annual income source of income, the current value of wealth, annual, investment plans, investment objectives, trading experience, and level of education.

• Financial data includes bank account and payment card details.

• Transaction data includes details about payments to and from you in relation to our services.

• Technical data includes internet protocol (IP) address, your login data, browser type, and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Services.

• Profile data includes your username and password, your interests, preferences, feedback, and survey responses.

• Usage data includes information about how you access our Services and use our Services, including user sessions (screen) recordings in some cases.

 3. Purposes for which we use personal data

We may only use your personal data if there is a lawful basis such as:

• performance of a contract: we will require your personal data to be able to offer you the Services in accordance with the contract terms between you and us;

• compliance with a legal obligation: due to the nature of the Services we provide, the laws applicable to our activities require us to collect and store certain data about you; and

• legitimate interests: sometimes we rely on our legitimate interests to process your data (e.g. to improve our Services).

We may use your personal data for the following purposes:

• To create your account

• To verify your identity, carry out checks that we are required to conduct by applicable laws and regulations, including: “know your customer” (KYC), anti-money laundering, fraud, sanctions, politically exposed person (PEP) and liveness checks and perform client risk categorization

• To obtain and assess economic profile and appropriateness information and categorise the client

• To provide our services and process transactions including, payments, fees and charges.

• To monitor your transactions for the purposes of detection, storage and reporting of fraudulent activities

• To provide customer support

• To send you service notifications related to your use of the Services

• To record and store communication with you

• To send you updates and marketing communication as well as to deliver relevant content to you, including ads, suggestions, personalised offers and recommendations

• To perform data analytics with respect to our Services for improvement purposes

• To manage and protect our business and website including system maintenance

• To help us improve our Services by completing a survey, feedback, or review

4. Disclosure of your information

We may share information we have collected about you in certain situations. Your information may be
disclosed as follows:

By Law or to Protect Rights

If we believe the release of information about you is necessary to respond to legal process, to investigate
or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we
may share your information as permitted or required by any applicable law, rule, or regulation. This
includes exchanging information with other entities for fraud protection and credit risk reduction.

Third-Party Service Providers

We may share your information with third parties that perform services for us or on our behalf, including
payment processing, data analysis, email delivery, hosting services, customer service, and marketing
assistance.

Affiliates

We may share your information with our affiliates, in which case we will require those affiliates to honor
this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or
other companies that we control or that are under common control with us.

5. Your rights

You may at any time review or change the information in your account or terminate your account by:

• Logging into your account settings and updating your account
• Contacting us using the contact information provided below
• Upon your request to terminate your account, we will deactivate or delete your account and
information from our active databases.

6. How long we will retain your personal information?

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy
unless otherwise required by law. We will keep your personal information for as long as you are a
customer of ours, and after you stop being one we will retain your information for the least amount of
time necessary to fulfill our legal or regulatory obligations and for our business purposes.
We may retain Personal Information for longer periods than required by law if it is in our legitimate
business interests and not prohibited by law or if we cannot delete it due to technical reasons.
We may also keep information for research or statistical purposes, in which case under no circumstances
will you be able to be identified from this statistical data, you will remain anonymous.

7. How do we protect your personal data?

We take all reasonable and appropriate technical and organizational measures to protect all personal data
collected by us from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction.

8. Changes

This Policy is subject to change and any changes to this Policy will become effective when posted on this
application. Your use of the application following these changes means you accept the revised Policy.

CONTACT US

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

Address: 10 Vazgen Sargsyan, “Piazza Grande” business center, office 101,
Email: info@apricotcapital.am
Phone: +374 (60) 70-71-11; +374 (98) 22-28-81