Financial digitization in Latin America: opportunity or urgency for banks and fintechs?

PRIVACY AND DATA PROTECTION POLICY

1. 1. GENERAL INFORMATIONINFORMATIONFUTSWAP MARKETS KOMMANDITBOLAG is a Swedish trust company - Global Trustee-, a limited liability company organized and existing under the laws of the Kingdom of Sweden, which for the purposes of these terms shall be referred to as FUTSWAP.INTERPRETATIONThe following definitions and rules of interpretation shall apply to customers or users who have a contractual relationship with FUTSWAP: Data Protection Legislation: means the data protection regulations enacted in English law (GDPR) as revised and replaced from time to time, Directive 2002/58/EC as updated by Directive 2009/136/EC and any other laws and regulations relating to the processing of personal data and privacy that apply to a party and, if applicable, guidance and codes of practice issued by the relevant supervisory or data protection authority. Personal Data Breach: Means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access to the Shared Personal Data. Shared Personal Data: Means the Personal Data to be shared between the parties by virtue of this contractual relationship. Access Request: Means the right by a Customer or User to access or request a copy of the Data provided pursuant to Article 15 of the GDPR. Supervisory Authority: means the relevant supervisory authority in the territories where the parties to this Agreement are established. PURPOSE The present privacy and data protection policies, constitute the regulatory framework for the provision of Personal Data made by the Customer or the User. Likewise, these policies define the principles and procedures to which users must adhere and the responsibilities to be assumed during the commercial relationship. FUTSWAP requires the personal data of clients and users for the fulfillment of its obligations and diligences pertinent to the registration and knowledge of the client and to comply with the legal obligations of prevention of Money Laundering, Financing of Terrorism and Transfer of Funds (Information on the Payer) Regulation 2017 and other related legislation. FUTSWAP undertakes to process the customer's and user's personal data only for the following purposes:

• • (a) FUTSWAP's performance of its obligations under this business relationship; (b) Complying with all of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and any other applicable legislation. FUTSWAP will not process Users' personal data without the User's prior permission for purposes other than those previously stated.FUTSWAP will ensure users' compliance with applicable national data protection laws at all times during the term of the business relationship. It is noted and should be noted that in the event of a conflict between the data protection law of the United Kingdom and the data protection law of the customer's country of domicile, the law of the country that provides greater protection for the privacy and personal data of users will be preferred.SHARED PERSONAL DATAThe following types of Personal Data will be shared by users during the Term of the business relationship: name, address, date of birth, identification document numbers (such as driver's license or passport), photograph of the Customers (if natural persons) and of the directors and beneficial owners of the customer (if legal entities). Personal Data shared by customers and users will not be used for purposes other than those already agreed.DATA PROCESSINGFUTSWAP will ensure that it processes the personal data of shared customers and users in a fair and lawful manner.lawful manner. To the same extent it will ensure that it has the respective powers in accordance with the Data Protection legislation for the processing of the Shared Personal Data. Data protection legislation, for the processing of Shared Personal Data. The user is obliged to provide clear, truthful, real and sufficient information to FUTSWAP for the fulfillment of the purposes already the purposes already established, in the same way, expressly authorizes FUTSWAP to process his or her personal data directly or by means of directly or through a third party, for which the user also authorizes FUTSWAP to process his or her personal data directly or through a third party, for which the user also authorizes FUTSWAP to process his or her personal data directly or through a third party. FUTSWAP to share or transfer the personal data provided to a third party. If the Personal transferred outside of the EEA, FUTSWAP will fully inform the user of such transfer, the purpose of such transfer about such transfer, the purpose of such transfer and the security measures implemented by FUTSWAP to enable the transfer to take place. FUTSWAP to enable the customer to be fully aware of and understand the purpose and risks of such transfer. FUTSWAP undertakes to inform its users, in accordance with the Data Protection Legislation, of the purposes for which it will process their personal data, the legal basis for such purposes and any other information that may be required. purposes for which it will process their personal data, the legal basis for such purposes and any other information required by Article 14 of the GDPR, including required by Article 14 of the GDPR, which includes: (a) whether the Personal Data shared will be transferred to a third party, that fact and sufficient third party, that fact and sufficient information about such transfer and the purpose of such transfer to enable the data subject to understand. the purpose of such transfer. (b) If the Personal Data will be transferred outside the EEA, that fact and sufficient information about such transfer and the purpose of such transfer to enable the data subject to understand the purpose and risks of such transfer. the purpose and risks of such transfer. (b) If the Shared Personal Data will be transferred outside of the EEA, this fact and sufficient information about such transfer, the purpose of such transfer, and the security measures implemented by FUTSWAP to enable the user to understand the purpose and risks of such transfer. said transfer. RIGHTS OF THE DATA HOLDER FUTSWAP undertakes to provide the necessary assistance and to allow users who own the data exercise their protection rights under the legal regulations, this within the time limits imposed by the Data Protection Legislation.   FUTSWAP will be responsible for keeping a record of individual requests for information, decisions taken and any information that has been exchanged with users. The records will include copies of the request for information, details of the data accessed and shared and, where appropriate, notes of any meeting, correspondence or phone calls related to the application. DATA RETENTION AND DELETION FUTSWAP will not retain or process Personal Data shared before or after user's business relationship, however, FUTSWAP will continue to retain Personal Data shared in accordance with applicable regulatory, professional and/or industry retention periods. FUTSWAP will ensure that all shared Personal Data is returned to the user or destroyed once the processing of the Personal Data is no longer necessary for the fulfillment of the purposes for those that were initially shared. Following deletion of Shared Personal Data in accordance with FUTSWAP will notify the user that the Shared Personal Data in question has been deleted. DATA TRANSFERS The transfer of personal data means any exchange of personal data by FUTSWAP with a third party, and will include, among others, the following items: (a) Subcontract the processing of Personal Data shared; (b) Grant a third party controller access to Shared Personal Data. FUTSWAP will designate to a third party processor to process the Shared Personal Data, for which you will comply with Article 28 and Article 30 of the GDPR. FUTSWAP may not transfer the Customer's Shared Personal Data to a third party located outside the EEA, with exception of the following requirements: (a) The third party complies with the provisions of articles 26 of the RGPD (in case the third party is a joint controller); Y. (b) ensures that: (i) The transfer is to an approved country by the European Commission as a provider of adequate protection in accordance with article 45 of the RGPD; (iii) there are appropriate safeguards in accordance with article 46 of the GDPR; or (iii) one of the exceptions for specific situations in the article 49 of the GDPR applies to the transfer. SECURITY AND DATA PROTECTION User will only provide Shared Personal Data to FUTSWAP using secure methods. For its part, FUTSWAP undertakes to take all appropriate technical and organizational security measures

2. 2. My personal data may/will be disclosed by Futswap Markets KB to its third party service providers or agents (including its lawyers/law firms), for one or more of the Purposes, as such third party service providers or agents, if engaged by Futswap Markets KB, would be processing my personal data for Futswap Markets KB for one or more of the Purposes.

2. 2. By clicking ACCEPT, I represent and warrant that I am the user and/or subscriber of the phone and email address as set out in my application form, account opening documents and/or otherwise provided by me or possessed by Futswap Markets KB, and that I have read and understood all of the above provisions, including the Personal Data Protection Terms and Conditions.

2. 2. Regional restrictions: Albania, Barbados, Birmania/Myanmar, Burkina Faso, Corea del Norte, Emiratos Arabes Unidos, Filipinas, Gibraltar, Haití, Irán, Islas Caiman, Jamaica, Jordania, Malí, Mozambique, Nigeria, Panama, Republica Democrática del Congo, Senegal, Siria, Sudáfrica, Sudán del Sur, Tanzania, Turquía, Uganda, Yemen, American Samoa, Anguilla, Dominica, Fiji, Guam, Palau, Samoa, Seychelles, Trinidad and Tobago, US Virgin Islands, Vanuatu.