Privacy Policy

Last Updated: January 14, 2026

EMOOLA LTD ("we," "our," or "us") operates the PFX MARKETS platform and associated services. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and services.

Please read this Privacy Policy carefully. By accessing or using our services, you agree to the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use our services.

1. Information We Collect

1.1 Information You Provide

We collect information that you voluntarily provide to us when you:

• Register for an account
• Use our services
• Contact us for support
• Participate in surveys or promotions

This information may include:

• Name and contact information (email address, phone number)
• Account credentials (username, password)
• Identity verification information (as required by financial regulations)
• Transaction and financial information
• Communications you send to us

1.2 Automatically Collected Information

When you access our services, we automatically collect certain information, including:

• Device information (device type, operating system, unique device identifiers)
• Usage data (features accessed, time spent, interaction patterns)
• Location data (with your permission)
• Log data (IP address, browser type, access times)
• Cookies and similar tracking technologies

2. How We Use Your Information

We use the information we collect for the following purposes:

2.1 Service Provision

• To create and manage your account
• To provide and maintain our services
• To process transactions and send related information
• To provide customer support

2.2 Communication

• To send you technical notices and updates
• To respond to your inquiries and requests
• To send you marketing communications (with your consent)
• To provide you with news and information about our services

2.3 Compliance and Security

• To comply with legal obligations and regulatory requirements
• To verify your identity and prevent fraud
• To detect, prevent, and address technical issues
• To protect the rights, property, and safety of EMOOLA LTD and our users

2.4 Service Improvement

• To analyze usage patterns and improve our services
• To develop new features and functionality
• To conduct research and analytics

3. How We Share Your Information

We may share your information in the following circumstances:

3.1 Service Providers

We may share your information with third-party service providers who perform services on our behalf, including:

• Payment processing
• Data analysis and analytics
• Identity verification
• Cloud storage and hosting
• Customer support services

3.2 Legal Requirements

We may disclose your information if required to do so by law or in response to:

• Valid legal processes (subpoenas, court orders)
• Regulatory inquiries or investigations
• Requests from law enforcement or government authorities
• Protection of our rights or the rights of others

3.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction.

3.4 With Your Consent

We may share your information for any other purpose with your explicit consent.

4. Data Security

We implement appropriate technical and organizational measures to protect your information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Secure server infrastructure
• Regular security assessments and audits
• Access controls and authentication mechanisms
• Employee training on data protection

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

5. Data Retention

We retain your information for as long as necessary to:

• Provide our services to you
• Comply with legal, regulatory, or contractual obligations
• Resolve disputes and enforce our agreements
• Maintain business records for legitimate purposes

When your information is no longer needed, we will securely delete or anonymize it in accordance with applicable laws and regulations.

6. Your Rights and Choices

6.1 Access and Correction

You have the right to access, update, or correct your personal information. You can do this by:

• Logging into your account and updating your profile
• Contacting us using the information provided below

6.2 Data Portability

You have the right to request a copy of your personal information in a structured, commonly used, and machine-readable format.

6.3 Deletion

You have the right to request deletion of your personal information, subject to certain legal exceptions (such as compliance with legal obligations or resolution of disputes).

6.4 Marketing Communications

You can opt out of receiving marketing communications by:

• Following the unsubscribe instructions in any marketing email
• Adjusting your account notification settings
• Contacting us directly

6.5 Cookies

You can control cookies through your browser settings. However, disabling cookies may affect the functionality of our services.

7. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that differ from those in your country.

We ensure that such transfers are conducted in accordance with applicable data protection laws and that appropriate safeguards are in place to protect your information.

8. Children's Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child, we will take steps to delete such information promptly.

9. Third-Party Links and Services

Our services may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to read the privacy policies of any third-party services you access.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, regulatory, or operational reasons. We will notify you of any material changes by:

• Posting the updated Privacy Policy on our website
• Updating the "Last Updated" date at the top of this policy
• Sending you an email notification (for significant changes)

Your continued use of our services after any changes indicates your acceptance of the updated Privacy Policy.

11. Legal Basis for Processing

We process your personal data based on the following legal grounds (in compliance with GDPR and applicable international data protection regulations):

• Contractual Necessity: Processing necessary to provide our services to you
• Legal Obligation: Processing required to comply with applicable laws and regulations
• Legitimate Interests: Processing necessary for our legitimate business interests (such as fraud prevention, service improvement)
• Consent: Processing based on your explicit consent (which you can withdraw at any time)

12. Complaints and Disputes

If you have concerns about how we handle your personal information, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.

For UK users, you can contact the Information Commissioner's Office (ICO) at: ico.org.uk

13. Definitions

"Personal Information" means any information that identifies or can be used to identify you, directly or indirectly.

"Services" refers to the PFX MARKETS platform, our mobile application, website, and any related services provided by EMOOLA LTD.

"You" refers to the individual accessing or using our services.