THE KABRU. PRIVACY AND COOKIE POLICY

At Kabru. (“Kabru.", "we", "us"), we process personal data about our customers, visitors on our websites. When you communicate with us or use our services ("you"), we do our best to handle your personal data with care, keep it secure and comply with data protection laws.

Kabru. is engaged in performance marketing, lead generation online and content publishing regarding financial information and services, with headquarters in Cyprus and subsidiaries in a number of other countries.

HOW THIS POLICY WORKS

The purpose of this Policy is to explain when, why and how we process information which may relate to you ("personal data"). It also provides important information on your statutory rights. This Policy is not intended to override the terms of any contract you have with us, nor rights you might have under data protection laws.

Click on a topic in the list below to find out more on individual topics. We have labelled sections of the Policy to make it easy for you to navigate to the information most relevant to you.

1. WHO IS RESPONSIBLE FOR LOOKING AFTER YOUR PERSONAL DATA?
2. WHAT PERSONAL DATA DO WE PROCESS?
3. WHAT DO WE USE YOUR PERSONAL DATA FOR AND WHEN DO WE PROCESS YOUR PERSONAL DATA?
4. WHO DO WE SHARE YOUR PERSONAL DATA WITH?
5. INTERNATIONAL TRANSFERS
6. DIRECT MARKETING
7. HOW LONG DO WE KEEP YOUR PERSONAL DATA?
8. WHAT ARE YOUR RIGHTS?
9. COOKIE POLICY (APPENDIX A)
10. EMAIL DISCLAIMER (APPENDIX B)

Kabru. with its registered address John Kennedy Street, IRIS HOUSE, 3rd Floor, 3106 Limassol, Cyprus is principally responsible for looking after your personal data (your Data Controller). Data Controller means the company that determines the means and purposes of processing of personal data.

Note that while we are principally responsible for looking after your personal data, information may be held in databases which can be accessed by other companies. When accessing your personal data, all companies will comply with the standards set out in this Policy.

Kabru. is a group of companies with subsidiaries in several countries, for example in the European Union, the United Kingdom and Africa.

We may process the following personal data about you:

• Name
• Email address
• Postal address
• IP address
• Location data
• Website usage
• Gender
• Age
• Occupation and place of work
• Information that you choose to provide us with, for example personal information about yourself, preferences and interests.

Kabru. will collect information directly from you when you communicate with us, use our services or visit our websites.

We use your personal data to:

• Send you press releases, financial reports and other corporate material relating to Kabru. See also Section 6 below on Direct Marketing.
• Send you information or invitations for events related to Kabru.
• Communicate with you, for example by phone or email.
• Analyse information in our systems and databases to improve the way we run our business and websites according to user preferences, to provide a better service and user experience.
• If we make available, register you for a chat forum or community in which you can provide comments.
• Meet or exercise any of our legal obligations or rights.

We will only process your personal data for the purposes set out in this Section 3 and where we are satisfied that:

• You have provided your consent to us using the data in that way, or
• our use of your personal data is necessary to support 'legitimate interests' that we have as a business (for example, to be able to carry out our business, improve our products, or to carry out analytics across our datasets), in a way that is proportionate and respects your privacy, or
• perform obligations and exercise rights under a contract that we have with you or the organisation you work for or represent.

We work with many third parties, to help manage our business and deliver services. These third parties may from time to time need to have access to your personal data:

• Our mailing application provider, Google Workspace;
• Our cloud infrastructure provider, Google Cloud, may process personal data on our behalf;
• Our analytics service providers, who process personal data for their own purposes as Data Controllers. Please refer to our Cookie Policy in the Appendix below in order to identify how you may prevent access to your personal data by analytics providers.
• Service providers or data processors that handle your personal data on our instructions, for example cloud services, advisers and consultants.
• Our subsidiaries in the Kabru. group, located inside or outside the EU/EEA.
• If we are under a duty to disclose to comply with a legal obligation or protect our interests or security.
• In the event we sell, buy or re-organise any business or assets, or if our assets are acquired by a third party, including prospective sellers or buyers.

International Transfers mean that personal data is transferred to a country outside the European Union.

As set out in Section 4 above, we may allow access to your personal data to third parties who may be located outside the European Union.

We may also disclose your personal data if we receive a legal or regulatory request from a foreign law enforcement body outside the European Union.

We will always take steps to ensure that any international transfer of information is managed to protect your rights and interests. Any requests for information that we receive from law enforcement or regulators will be carefully checked before personal data is disclosed.

You have the right to ask us for more information about the safeguards we have put in place as mentioned above. Contact us (see Section 8) if you wish further information.

We will use your personal data to send you direct marketing communications regarding Kabru. This may be in the form of email or targeted online advertisements.

In some cases, our processing of your personal data for marketing purposes will be based on our legitimate interests (see Section 3 above). When required by law it will be based on your consent.

You always have a right to say no to further direct marketing, at any time. You can use the opt-out link that you find in all direct marketing communications, or by contacting us (see Section 8).

We take steps to limit direct marketing to a reasonable and proportionate level, and to send you communications that we believe may be of interest or relevance to you, based on the information we have about you.

We will retain your personal data for as long as reasonably necessary for the purposes listed in Section 3 of this Policy.

In some circumstances we keep your personal data during a certain period to meet, for example, legal, tax or accounting requirements.

We maintain a data retention policy for personal data in our care. Where your personal data is no longer required, we will ensure it is either securely deleted or made anonymous.

You have a number of rights in relation to your personal data. More information about each of these rights can be found by referring to the table set out further below.

To exercise your rights you may contact us by sending an email to privacy@kabru.com.

Please note the following if you wish to exercise your rights:

RIGHT	WHAT THIS MEANS
Access	You can ask us to: Confirm whether we are processing your personal data; Give you a copy of that data; Provide you with other information about your personal data, for example what data we have, what we use it for, who we disclose it to, whether we transfer it outside the EU and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any Automated Decision Making or Profiling, to the extent that information has not already been provided to you in this Policy.
Rectification	You can ask us to rectify inaccurate personal data. We may seek to verify the accuracy of the data before rectifying it.
Erasure	You can ask us to erase your personal data, but only where: It is no longer needed for the purposes for which it was collected; or you have withdrawn your consent (where processing was based on consent); or following a successful right to object (see 'Objection' below); or it has been processed unlawfully; or to comply with a legal obligation. We are not required to comply with your request to erase your personal data if the processing of your personal data is necessary: for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims; There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances in which we would deny that request.
Restriction	You can ask us to restrict (i.e. keep but not use) your personal data, but only where: its accuracy is contested (see Rectification), to allow us to verify its accuracy; or the processing is unlawful, but you do not want it erased; or it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or you have exercised the right to object, and verification of overriding grounds is pending. We can continue to use your personal data following a request for restriction, where: we have your consent; or to establish, exercise or defend legal claims; or to protect the rights of another natural or legal person.
Portability	You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it 'ported' directly to another Data Controller, but in each case only where: the processing is based on your consent or on the performance of a contract with you; and the processing is carried out by automated means.
Objection	You can object to any processing of your personal data which has our 'legitimate interests' as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. We have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
International Transfers	You can ask to obtain a copy of, or reference to, the safeguards under which your personal data is transferred outside of the European Economic Area. We may redact data transfer agreements or related documents (i.e. obscure certain information contained within these documents) for reasons of commercial sensitivity.
Supervisory Authority	You have a right to lodge a complaint with the responsible local supervisory authority about our processing of your personal data. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

Why do we use Cookies?

We use “cookies” to offer you a full range of functions when you visit our website, recognize your preferences, and make the use of our website more comfortable and convenient.

What are Cookies?

A cookie, pixel or similar technology is a small file or information that is saved on your computer or device when you visit the website. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

Your options

By using our website, you agree to the use and storage of cookies on your computer or device.

You can generally view our website without cookies, but certain parts of the website may not work properly or navigating be slower.

If you do not wish cookies to be stored on your computer or device, you can deactivate the relevant option in the system settings of your browser. You can also delete stored cookies in the system settings of your browser at any time.

More information on how to deactivate or delete cookies can be found here: https://www.aboutcookies.org/cookie-faq/. However, please keep in mind that if you do not accept any cookies this may restrict the functionality of our offerings.

Categories of cookies

We use cookies for different purposes and with different functions.

Some cookies are:

1. necessary in technical terms (Technical Necessity)
2. stored and used for a certain time period (Storage Duration)
3. placed and stored by us or a third party (Cookie Provider).

1. Technical Necessity

   • Cookies that are technically necessary: We use certain cookies because they are strictly necessary in order for the website and its functions to work properly. These cookies are automatically placed on your computer or device when you access the website or a certain function, unless you have set your browser to reject cookies.
   • Not necessary: Cookies that are not strictly necessary are placed on your computer or device to improve convenience and performance of our website or save certain settings that you have made. We also use cookies that are not strictly necessary in technical terms to get information on the frequency of use of certain areas of our website, so that we can adapt to your needs and requirements on a more targeted basis.

2. Storage Duration

   • Session cookies: Some cookies are only needed for the duration of your website session and are thus called “session cookies”. They will be erased or become invalid as soon as you leave our website or when your current session expires. Session cookies are used, for example, to retain certain information during your session.
   • Permanent cookies: Some cookies are stored for a longer period. For example, the cookie allows us to recognize you when you access our website again and access saved settings. As a result, you can access web pages faster or with greater convenience, for example that you do not need to set certain options again, such as your chosen language. Permanent cookies are automatically deleted after a predefined period.
   • Flow cookies: These cookies are used for communication between our internal servers within our company group. They are placed on your computer or device when you start navigating the website and are deleted after the end of your navigation on the website. Flow cookies are given a unique identification number but they do not allow us to draw any conclusions regarding the actual customer or user.

3. Cookie Provider

   • Provider cookies: These cookies are placed by us or the operator of our website, who is commissioned by us.
   • Third-party cookies: “Third-party cookies” are stored and used by other organisations or websites, for example, web analytics tools. External providers may also use cookies to display advertising or to integrate content from social networks, such as social plugins. For further information on web analytical tools and measurement of reach, please see below.

Use of cookies for Web Analytics and Reach Measurement

We use Google Analytics, a Web analytics service of Google Inc. (“Google”). Google Analytics uses cookies to identify the frequency of use of certain areas of our website and to identify preferences. The information regarding your use of this website that is generated by the cookie (including your truncated IP address) is transferred to a Google server in the United States and stored there. Google will use this information to analyse your use of the website, compile reports on website activity for us, and perform further services associated with website use and Internet use. Google may also transmit this information to third parties where required by law or to third parties process these data on behalf of Google.

You can deactivate Google Analytics using a browser add-on if you do not wish the website analysis to take place. You can download the add-on here: https://tools.google.com/dlpage/gaoptout?hl=.

This add-on stores “opt-out” information on your device that serves to match up your deactivation of Google Analytics. Please note that this kind of “opt out” only leads to the deactivation of Google Analytics for the device and browser from which the opt out was activated. In addition, you may need to reactivate it if you delete cookies from your device.

Our most common cookies are as follows:

NAME OF COOKIE	COOKIE PROVIDER	PURPOSE
Google Analytics	Google	This Cookie is placed by Google. It enables our website to learn information about our users’ use of our site, such as the time of visit, the pages viewed, whether the user has visited before and the websites visited prior to visiting ours.
Facebook Pixel	Facebook	This Cookie is placed by Facebook. It enables our website to measure, optimise and build audiences for advertising campaigns served on Facebook.
One Signal	One Signal	This Cookie is placed by One Signal. It enables our website to remember that you subscribed to receive push notifications. It also helps us deliver personalised notifications.
VWO	VWO	This Cookie is placed by VWO. VWO places cookies in end user’s and customer’s browser to identify the user. Cookies do not contain any of your personal data. They may also collect and store information locally on your device, using mechanisms such as browser web storage.
Hotjar	Hotjar	This Cookie is placed by Hotjar. It collects non-personal information, with the overall aim of providing you with a better website experience, diagnosing technical problems and analysing trends.
AdWords	AdWords	AdWords is used to enable Google PPC (pay per click) campaigns.
Double Click	Double Click	Double Click is used for advertisers and to advertise on multiple ad servers.

The information contained in this communication is confidential and may be legally privileged. It is intended solely for the person or entity to whom or which it is addressed. If you are not the intended recipient of this message, be aware that any use, review, retransmission, distribution, reproduction, or any action taken in reliance upon this message is strictly prohibited. Disclosure and / or use may lead to civil liability.

If you have received this message in error, please notify the sender immediately by replying to this e-mail or by telephoning the sender and thereafter permanently deleting this message and any attachments to it.

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Personal views and opinions expressed in this message are solely those of the author and do not necessarily represent those of KABRU.

KABRU. does not accept liability for any errors, omissions, or offensive content in this message.