1. INTRODUCTION

Kucherov Pavel Sergeevich provides software as a service that allows you to use several features to familiarize yourself with algo trading and automated trading robots. This Privacy Policy explains how the OpexFlow website operates, email support@opexflow.com (“OpexFlow”, “our”, “we”, or “us”) as the personal data controller collects and processes your (“you”) personal data when you visit the https://opexflow.com/ or https://articles.opexflow.com website (“Website”). If you are a signal provider, please see our privacy notice for signal providers. Capitalized terms in this Privacy Policy are used with the meaning given to them in the Terms of Use,

2. DATA WE COLLECT

2.1 Technical data When you visit our Website, we process technical data related to your use of the Website, including, but not limited to, IP address, location data (up to city level), access provider, link URL, date , time, access tokens, session key, browser type and version, browser language, operating system, amount and status of data transferred. This information may be associated with you, so personal information may also be processed. This data may also be processed as de-identified statistical data. 2.2 Cookie Data We use cookies on the Website to optimize the Website and its features. Cookies may collect your personal information. To learn more about the cookies we use, please see our Cookie Policy. 2.
2.4 When you use the Software2.4.1 Personal identification information Name, email address, 2FA key, IP address, broker tokens, language, Google Analytics client ID, Gravatar image, if you choose to register with Facebook, we collect your Facebook UID, Facebook profile name, address Facebook email address, if you choose to sign up with Apple, we collect your Apple profile name, Apple email address, or an Apple-generated email address. If you register through the mobile app, we collect information about your device language, device region, device type and model. 2.4.2 Financial and transactional data Account username, API key, API secret, passphrase, transaction data (date/time/transaction amount), transaction request/response, referral status, payment information (country, phone number, address, city, postal code;) The personal data we process is collected from one of the following sources: the data is disclosed by you directly to us; we receive data from your broker account provider in connection with you connecting your accounts to a client account; we receive data from a social media service provider in connection with you registering or contacting us through an existing social media account; we receive data from the payment service provider in connection with the fact that you have entered into a Sales Agreement and paid for the Subscription; we automatically receive Technical Data from your browser, our servers and systems; the data is disclosed by you directly to us; we receive data from your broker account provider in connection with you connecting your accounts to a client account; we receive data from a social media service provider in connection with you registering or contacting us through an existing social media account; we receive data from the payment service provider in connection with the fact that you have entered into a Sales Agreement and paid for the Subscription; we automatically receive Technical Data from your browser, our servers and systems; the data is disclosed by you directly to us; we receive data from your broker account provider in connection with you connecting your accounts to a client account; we receive data from a social media service provider in connection with you registering or contacting us through an existing social media account; we receive data from the payment service provider in connection with the fact that you have entered into a Sales Agreement and paid for the Subscription; we automatically receive Technical Data from your browser, our servers and systems; that you register or contact us through an existing social media account; we receive data from the payment service provider in connection with the fact that you have entered into a Sales Agreement and paid for the Subscription; we automatically receive Technical Data from your browser, our servers and systems; that you register or contact us through an existing social media account; we receive data from the payment service provider in connection with the fact that you have entered into a Sales Agreement and paid for the Subscription; we automatically receive Technical Data from your browser, our servers and systems;

3. What we use your personal data for

fulfillment of the Purchase Agreement Sending newsletters to your email Providing you with notifications through a channel of your choice (e.g. mobile app, email, website, Telegram Bot) Data processing for predictive analytics and insights, improvement and development of the Software All categories of data referred to in section 2 above Diagnosing and fixing technical problems related to the Software and the Website. Ensuring data security and preventing fraudulent activities related to the Software and the Website; ensuring the functioning of the Software and the Site Storing information containing personal data in backup systems Disclosing data to potential business buyers, including legal advisers,

4. TRANSFER OF YOUR PERSONAL DATA

Any data you provide will not be publicly displayed or shared with other visitors or customers of the Website. In the table below, we have set out the reasons why and with whom we share your personal information: We work with service providers who work on our behalf and who may need access to certain personal information in order to provide their services to us. These companies include those we have hired to operate the technical infrastructure we need to provide our services, help protect and secure our systems and services, and market our services. Most of the above service providers are located in the European Union or the European Economic Area, however, some of these service providers are based in the United States and the Russian Federation. Standard contractual clauses or other applicable means shall apply to secure the transfer. We will share your personal data with our payment processors as necessary to enable them to process your payments. We work with advertising partners so that we can customize the advertising content you may receive. These partners help us provide you with more relevant advertising and promotional messages, which may include interest-based advertising (also known as online behavioral advertising), contextual advertising, and generic advertising. We and our advertising partners process certain personal data to help us understand your interests or preferences so that we can deliver advertising, which is more relevant to you. We also provide you with email campaigns related to our services (educational videos, etc.) using an email campaign service provider. To do this, we may share your email address with such service provider so that they can send content to you. Potential business buyers and business successor(s) Where necessary and required for the successful transfer of our business or for the purposes of mergers and acquisitions, your Personal Data may be disclosed to said acquirers and their representatives and/or legal advisors. This is done on the basis of our legitimate interests in the sale and reorganization of our business activities. related to our services (educational videos, etc.) using an email campaign service provider. To do this, we may share your email address with such service provider so that they can send content to you. Potential business buyers and business successor(s) Where necessary and required for the successful transfer of our business or for the purposes of mergers and acquisitions, your Personal Data may be disclosed to said acquirers and their representatives and/or legal advisors. This is done on the basis of our legitimate interests in the sale and reorganization of our business activities. related to our services (educational videos, etc.) using an email campaign service provider. To do this, we may share your email address with such service provider so that they can send content to you. Potential business buyers and business successor(s) Where necessary and required for the successful transfer of our business or for the purposes of mergers and acquisitions, your Personal Data may be disclosed to said acquirers and their representatives and/or legal advisors. This is done on the basis of our legitimate interests in the sale and reorganization of our business activities. Potential business buyers and business successor(s) Where necessary and required for the successful transfer of our business or for the purposes of mergers and acquisitions, your Personal Data may be disclosed to said acquirers and their representatives and/or legal advisors. This is done on the basis of our legitimate interests in the sale and reorganization of our business activities. Potential business buyers and business successor(s) Where necessary and required for the successful transfer of our business or for the purposes of mergers and acquisitions, your Personal Data may be disclosed to said acquirers and their representatives and/or legal advisors. This is done on the basis of our legitimate interests in the sale and reorganization of our business activities.

5. SECURITY OF PERSONAL DATA

We have adopted the necessary technical and organizational security measures to protect your personal data from accidental or unlawful destruction, loss or alteration, as well as from unauthorized disclosure, misuse or other processing in violation of applicable law. We also recommend that you take steps to ensure the security of your personal data. In particular, we advise you not to share your personal data with us or any of our partners through any public forums or other public channels, unless you acknowledge and agree that the relevant data will be publicly available.

6. RETENTION AND DELETION OF PERSONAL DATA

Your personal data (all categories of data referred to in Section 2) must be kept to the extent reasonably necessary to achieve the purposes set out in Section 3 above, or for as long as the obligation requires us to do so. In order to determine the appropriate personal data retention period, we consider the scope, nature and confidentiality of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes of processing and whether those purposes can be achieved through other means, and applicable statutory obligations. When storing personal data, we take into account the real need to resolve disputes and enforce the contract between us or to anonymize your personal data and keep this anonymous information indefinitely. If you are a Client, we will generally retain all of your data for 7 days after the termination of the Client Agreement so that you can reactivate the client account. Otherwise, please see the following partial description of how we store your personal data: For accounting purposes, we store Financial Data and Transaction Data and associated personal identification information for 7 years from the end of the financial year in which the relevant business transaction took place; Data, associated with a Customer Agreement or a Purchase Agreement, which is primarily Personal Identifiable Information, is retained for the duration of the relevant agreement and for at least 3 years from the date of termination of the relevant agreement in accordance with our legitimate interests, to protect ourselves from potential disputes or ensure compliance. If we have reasonable doubt that a party has acted in bad faith, intentionally breached any obligation or threatened us with a dispute, we may extend such retention period for a maximum of 10 years. Technical data will be kept for 30 days from the date of collection of such data; Communication Data, unless explicitly linked to a Customer Agreement or a Purchase Agreement, will be kept for 3 years from the date of closing the relevant communication flow. In the event that any of the data referred to in Section 2 above is necessary for the purposes of defending against current or potential disputes, we will retain the relevant data until the dispute is resolved. After the expiration of the retention period defined above, or the termination of the legal basis for the purposes of processing, we may store materials containing personal data in backup systems, from which the relevant materials will be deleted after the end of the backup cycle. We ensure that appropriate security measures are in place during the backup period and that the stored material is not used. necessary for the purposes of defending current or potential disputes, we will retain the relevant data until the dispute is resolved. After the expiration of the retention period defined above, or the termination of the legal basis for the purposes of processing, we may store materials containing personal data in backup systems, from which the relevant materials will be deleted after the end of the backup cycle. We ensure that appropriate security measures are in place during the backup period and that the stored material is not used. necessary for the purposes of defending current or potential disputes, we will retain the relevant data until the dispute is resolved. After the expiration of the retention period defined above, or the termination of the legal basis for the purposes of processing, we may store materials containing personal data in backup systems, from which the relevant materials will be deleted after the end of the backup cycle. We ensure that appropriate security measures are in place during the backup period and that the stored material is not used. containing personal data in backup systems, from which the relevant materials will be deleted after the end of the backup cycle. We ensure that appropriate security measures are in place during the backup period and that the stored material is not used. containing personal data in backup systems, from which the relevant materials will be deleted after the end of the backup cycle. We ensure that appropriate security measures are in place during the backup period and that the stored material is not used.

7. YOUR RIGHTS AND PREFERENCES

You have rights under data protection law, including: The right to information and access. You can receive information about your personal data processed by us. Right to data portability. You have the right to receive your personal data from us in a structured, commonly used and machine-readable format. In addition, you can request the transfer of personal data to another controller. Keep in mind that the latter can only be done if it is technically possible. Right to erasure. You have the right to delete the personal data we process about you from our systems if the personal data is no longer needed for the relevant purposes. The right to object and restrict. You have the right to object to the processing of your personal data and to restrict it in certain cases. Right to Correction. You have the right to correct your personal data. The right to withdraw consent. Once you have given us consent to process your personal data, you can withdraw that consent at any time. The right to appeal to the supervisory authority. If you are not satisfied with our response to your request regarding Personal Data, or if you believe that we are not processing your Personal Data in accordance with the law, you can file a complaint. To exercise any of the aforementioned rights, please contact our customer service team at the email address provided in Section 8 below. Please note that in the event that you are requesting the exercise of the rights described above or any other rights related to our services on behalf of anyone (legal representative, close relative of a deceased client, etc.), we have the right to ask you for additional information to confirm permission for such a request (signed authorization from the client, ID of the requester, death certificate, etc.). Such additional information is necessary to protect the personal data and financial interests of our customers.

8. OTHER IMPORTANT INFORMATION

With your express consent, you may participate in direct marketing campaigns, we may send you our newsletter or provide you with notices. You can opt out of direct marketing campaigns, newsletters and notifications in your account settings. We may also provide you with news, special offers and general information about other goods, services and events we offer that are similar to those you have already purchased or inquired about, unless you have opted out of receiving such information. Please note that marketing email messages include an opt-out mechanism in the message itself (for example, an unsubscribe link in emails we send to you). By clicking on the link in the email, you will opt out of further communications in this category. You can use the Account Settings page to select all email and push notification categories. Dispute Resolution If you have questions, please contact us at support@opexflow.com. Disputes related to the processing of personal data are resolved using our Complaint Procedure. We may change this Privacy Policy from time to time to reflect changes in how we process personal data. In the event of material changes, we will notify you as required by applicable law. Age Restrictions We do not knowingly collect any information from anyone under the age of 18. If we detect that a user is under the age of 18, we will require the user to close their account,