I. Introduction and overview

This Policy describes the user data that Green Tiger Software Inc. (dba Green Tiger Markets, and together with its affiliates, “GTM”) collects, how it is used and shared, and your choices regarding this data. Please note that by accessing GTM’s website and/or using any GTM services, you consent to all the provisions of this Policy. All those subject to this Policy are referred to as “users” in this notice.

GTM is the data controller for personal data collected in connection with use of GTM’s services and website. GTM may use third parties to collect and process user data, and user data may be stored on servers (whether physical or virtual) maintained either by GTM or by third parties (including without limitation third-party hosting vendors). We reserve the right to store and process personal data anywhere in the world.

II. Data collections and uses

A. The Data We Collect

• Data provided by users to GTM, such as during account creation and website usage
• Data created during use of our services and website, such as location and device data
• Data from other sources, such third parties that use GTM APIs

1. Data provided by users. This includes:

• User profile: We collect data when users create or update GTM accounts, including without limitation on the GTM website or for the GTM Marketplace. This may include without limitation name, email, phone number, login name and password, address, payment or banking information (including related payment verification information), and government identification documents (including without limitation photographs), and any other information requested in GTM Marketplace onboarding documents.
• Background check and identity verification: We may collect background check and identity verification information as part of GTM’s onboarding processes.
• Demographic data: We may collect demographic data about users, including through user surveys. We may also receive demographic data about users from third parties.
• User content: We collect the information users submit when they contact GTM customer support.
• Communications with GTM and on the GTM Marketplace: We reserve the right to record all conversations (whether telephonic, by email, by instant message, or by any other means) related to a user’s use of GTM’s services including the GTM Marketplace.
• Transactions on GTM Marketplace: We collect and maintain information regarding bids, offers, and completed transactions on GTM’s Marketplace (directly or indirectly).

2. Data created during use of our services. This includes:

• Location data: We may collect precise or approximate location data from a user’s device if enabled by the user to do so.
• Usage data: We collect data about how users interact with our services (including the GTM website and the Marketplace). This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or services used before interacting with our services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers. GTM may use “Cookies” to do so.
• Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, and mobile network data.

3. Data from other sources. This includes:

• Publicly available sources.
• Marketing service providers.

B. How we use personal and other user data

• For customer support and to facilitate user and participant onboarding
• For research and development, including without limitation with respect to new features, products, services, and financial instruments
• To provide, maintain, and improve GTM services and features, including without limitation to troubleshoot bugs and operational problems, conduct data analysis, and monitor and analyze usage and activity trends
• To enable communications between users and Participants
• To send marketing and non-marketing communications to users and Participants
• To verify compliance with the Rules of the GTM Marketplace and applicable, including for Marketplace surveillance
• To provide to governmental authorities/agencies, regulators, and SROs upon their request
• In connection with legal proceedings
• To generate market data regarding financial instruments listed for trading on the GTM Marketplace
• To evaluate users’ and Participants’ use of GTM services, including to determine whether Participants meet required usage thresholds if any

C. Cookies and third-party technologies

• Authenticating users
• Remembering user preferences and settings
• Determining the popularity of content
• Delivering and measuring the effectiveness of marketing campaigns
• Analyzing site traffic and trends, and generally understanding the online behaviors and interests of users who interact with our services
• Other uses as determined from time to time by GTM

D. Data sharing and disclosure

• Payment processors and facilitators
• Background check and identity verification providers
• Cloud storage providers
• Marketing partners and marketing platform providers
• Data analytics providers
• Research partners, including those performing surveys or research projects in partnership with GTM or on GTM’s behalf
• Vendors that assist GTM to enhance the safety and security of its platform
• Consultants, lawyers, accountants, compliance and regulatory services providers, and other professional service providers

E. Data retention and deletion

By default, GTM retains user profile, transaction-related (including without limitation, bid, offer, and completed transaction), and other personal and entity-related data indefinitely. Requesting Users (which means for this purpose (i) individuals who are not affiliated with Participants on GTM’s Marketplace, that (ii) are affiliated with entities that are no longer Participants on GTM’s Marketplace, or (iii) that have been authorized by the entity Participant on GTM’s Marketplace to request deletion of the Requesting User’s personal information) may request that GTM delete personal information with respect to the Requesting User, other than as GTM deems necessary to retain for purposes of applicable law, regulatory requirements, or to comply with GTM’s rules. For the avoidance of doubt, GTM will not delete records of any bids, offers, completed transactions, or other GTM Marketplace activity

III. Updates to this policy

We may from time to time update this policy and will provide notice to users (which may without limitation be via GTM’s website or “click-through” notice). Use of GTM’s or its affiliates’ services, including without limitation accessing the GTM website, after an update constitutes consent to the updated notice to the extent permitted by law.

IV. Certain Definitions

Refers to the marketplace operated or proposed to be operated by GTM, an affiliate thereof, or any successor thereto for trading in Forwards or other financial instruments.

An entity that GTM has been admitted for trading, and remains in good standing, on the Marketplace.