Privacy Policy

Terms and Conditions:

The Terms and Conditions consist of the following parts – please read them carefully:

FRAUD ALERT

PRIVACY POLICY.

(the “Privacy Policy“)

We respect the privacy of the users of our platform (the “Platform“) and/or our website at: www.an.gold and www.simplex.uk (the
Site(s)“, or the “Platform(s)“), and are committed to protect the personal
information that users share with us in connection with the use of our Platform and/or Site (collectively – the
Service“). This Privacy Policy (the “Privacy Policy“) is intended to describe
our practices regarding the information we collect from you (the “User” or
you“) when you use the Service (or any part thereof), the manners in which we may use your
personal information, and the options and rights available to you. Capitalized terms which are not defined
herein, shall have the meaning ascribed to them in our Terms and Conditions available at www.an.gold (the
TOU“), which this Privacy Policy is incorporated hereto by reference.The same definitions and abbreviations used in the “Terms and Conditions” apply here as well, with no restrictions. The contents of the “Terms and Conditions” is party of this chapter without restrictions.

“In this Privacy Policy,
you may learn about the following:

  1. Your Consent
  2. What Information we collect on our users
  3. How do we collect information on our users
  4. What are the purposes of the collection of Personal Information
  5. What are the Conditions for Processing of Personal Information
  6. Sharing Information with Third Parties
  7. Retention of Personal Information
  8. Minors
  9. Cookies & Local Storage
  10. Your Right
  11. Security
  12. Third Party Websites
  13. Changes to the Privacy Policy
  14. Have any Questions?

 

1. Your Consent (PLEASE READ CAREFULLY!).

By entering to, connecting to, accessing or using the Service (or any part thereof), you agree to the terms and
conditions set forth in this Privacy Policy, including to the collection and processing of your personal
information (as defined below). If you disagree to any term provided herein, you may not access and/or use the
Service in any manner whatsoever.

2. Which information may we collect on our users?

We collect two types of information from our Users:
Non-personal information

  • The first type of information is un-identified and non-identifiable information pertaining to a User(s),
    which may be made available or gathered via the User’s use of the Service and/or the transactions
    carried out in connection with the Service, including through an exchange’s website carrying the Service
    (“Exchange“), as applicable (“Non-Personal Information“). We are not
    aware of the identity of the User from which the Non-personal Information was collected.
  • Non-Personal Information which is being collected consists of technical information and aggregated usage
    information, and may contain, among other things, the User’s operating system, type of browser, screen
    resolution, browser and keyboard language, the User’s ‘click-stream’ on the Service and activities on
    the Service, the period of time the User visited the Service and related timestamps, etc.
  • Non-Personal Information shall be gathered by us in order to perform preliminary examinations of the
    users’ transactions before enabling such users to use the Service.
  • For the avoidance of doubt, any Non-personal Information connected or linked to any Personal Information
    shall be deemed as Personal Information as long as such connection or linkage exists.

Personal Information

  • The second type of information is information that identifies or may identify an individual with
    reasonable efforts (“Personal Information“). Personal Information which is being
    gathered may consist of the following:
  • The User’s IP address, as well as other persistent device identifiers, which is automatically recorded
    from the User’s device and used mainly for enhancing the User’s experience and for geolocation,
    personalization, security and fraud prevention purposes, as further detailed below.
  • In the event that following the preliminary examinations of Non-personal Information as noted above,
    such user is determined as qualified to use the Service (as shall be determined in our sole discretion),
    then after clicking the Service button the User will be requested to fill out the registration form
    available on the Service, and such User will be required to provide certain information such as his/her
    contact details, including the following:

    • Full name
    • Physical address
    • E-mail address
    • Copy of a government-issued ID (such as a passport or driver’s license) – this is collected as
      means for official proof of identity
    • Details regarding the government-issued ID, such as the number, issuing country and expiration
      date;
    • Country of residence
    • Gender
    • Date of birth
    • Billing address
    • Wallet ID (if applicable)
    • Credit card details – however, please note that such data is transmitted directly to our trusted
      third party payment processors. We do not retain the full details of the credit card.
    • Any additional required information in order to render the Service.
  • Kindly note that without providing the above information you may not be able to complete the
    transaction.
  • In addition, we also collect the User’s publicly-available social network information, provided that the
    User has an existing third-party social network account (namely, a Facebook, Twitter, LinkedIn or
    Google+ account) (“SN Account“) registered under the same name and/or e-mail provided
    by User when registering to the Service.
  • In the event a User registers to the Service or otherwise grants us with certain access permissions to
    his/her SN Account, the third-party social network(s) operating such SN Account(s) may provide us with
    certain information about the User, as is stored in and/or made available by the User through his/her SN
    Account and in accordance with the permissions granted to us by the User. For example, such information
    may consist, as applicable and/or made available by the User, of the User’s name, public profile picture
    URL address, SN Account User ID, e-mail address, date of birth, gender, occupation or work information,
    education and other information which the User made public.
  • In addition, we also collect the behaviour of the User on our Services, which includes keystrokes,
    recording of mouse movements and other activities in our Services.
  • Any Personal Information provided voluntarily by the User via its use of the Service, such as the User’s
    e-mail address in order to be contacted (and any additional information related to such contacts), User
    responses to customer surveys about how we can improve our product(s) and service(s), transaction
    details provided through use of the Service, and/or other actions performed by the User in connection
    with the Service.
  • We also collect additional data from third-party sources regarding the User. This includes the User’s
    credit rating and other information available through publicly available credit card blacklists and
    official limited bank account lists, as well as non-public information provided by credit rating
    agencies, banks or other organizations.

Kindly note that the Personal Information we collect is required in order for us to contractually provide the
Services, as well as for us to meet our regulatory requirements (such as Anti-Money Laundering and
Know-Your-Customer regulations), and to safeguard our legitimate interests. In the event that you will not
provide such information, we may not be able to provide our Services.

3. How Do We Collect Information on Our Users?

We use the following methods of collection:

  • We collect Non-Personal Information through your use of the Service and/or the transactions
    carried out in connection with the Service.
    In other words, when you are using the Service,
    including when you browse an Exchange, we may be aware of it and may gather, collect and record the
    information relating to such usage, either independently or through the help of third-party services as
    detailed below.
  • We receive Personal Information from the Exchange.For example, when you return to an
    Exchange, such Exchange may provide us with your contact information (such as name, address and date of
    birth), as well as usage information regarding your previous visits to its website(s) (for example, the
    User’s balance, previous logins and previous transactions).
  • We collect Non-Personal Information and Personal Information through publicly available
    sources.
    For example, we collect certain information about you through your publicly
    available SN Account(s) information, publicly available credit card blacklists and official limited bank
    account lists, and other online public information.
  • We obtain Personal Information from third-party services and from the Exchange.For
    example, we use third-party services to receive and enhance the User’s information.
  • We collect Personal Information which you provide us voluntarily.For example, we
    collect Personal Information required to use the Service by completing the registration form and/or
    contacting us directly.

We store the Personal Information either independently or through the help of our authorized third-party service
providers as detailed below.

4. What are the Purposes of the Collection of Information?

We collect Non-Personal Information and Personal Information in order to:

  • Provide and operate the Service, including for risk analysis, billing, and other aspects relating to
    carrying out the transactions performed by the Users (such as identity authentication, payment
    processing, and charge-backs);
  • Analytics, statistical and research purposes;
  • Detect, prevent, or otherwise address fraud, security or technical issues (such as identity theft or
    financial fraud);
  • Meet our regulatory requirements, such as Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”)
    regulatory requirements.
  • Enable us to further develop, customize and improve the Service based on Users’ common preferences and
    uses;
  • Create and provide our business partners and affiliates with aggregated statistical data;
  • Direct marketing purposes – we may use the contact details you provided us to send you promotional
    offers or communications; you may withdraw your consent via sending a written notice to us by
    email to the following address: legal@an.gold or on the same
    manner as the advertising was transmitted to you (e.g. via phone text message), or by following the
    unsubscription instructions on the promotional offer or communication.
  • Respond to User’s support requests;
  • Satisfy any applicable law, regulation, legal process, subpoena or governmental requests;
  • Enable us to provide our Users with a better user experience, with more relevant Content, features, and
    functionalities, and with technical assistance and support; and
  • Protect the rights, property, or personal safety of us, any of our Users, or the general public;
  • Enforce this Privacy Policy and/or the TOU, including investigation of potential violations thereof;
  • Abide by any applicable law.

5. What are the Conditions for Processing of Personal Information?

We will process your Personal Information for a variety of reasons, each of which is prescribed by relevant data
protection laws.

  • Fulfillment of a contract, compliance with a legal obligation – it is necessary for us to process your
    Personal Information where it is necessary for the performance of a contract (such as for the TOU) or in
    order for us to comply with our various legal and/or regulatory responsibilities, including, but not
    limited to, complying with any AML and KYC legislation).
  • Legitimate interests – we also process your Personal Information where we deem such processing to be in
    our (or a third party’s) legitimate interests and provided always that such processing will not
    prejudice your interests, rights and freedoms. Examples of us processing in accordance with legitimate
    interests would include: (i) where we disclose your Personal Information to any one or more of our
    associate/subsidiary companies following a restructure or for internal administrative purposes; (ii)
    processing for the purposes of ensuring network and information security, including preventing
    unauthorized access to our electronic communications network; (iii) safeguarding the integrity of our
    Service by combating, reporting and sharing information related to fraudulent activities; (iv) adhering
    to regulatory and statutory requirements; (v) sharing personal information with our advisers and
    professional services providers (such as auditors) for ensuring our compliance with regulatory
    requirements and industry best practices.
  • Consent – our processing of your Personal Information will primarily be necessary for us to provide you
    with the Service. However, on certain occasions we may ask for your consent to processing Personal
    Information. In these instances your Personal Information will be processed in accordance with such
    consent and you will be able to withdraw this consent in writing at any time.
  • Special Categories of Personal Data our processing of your Personal Information may
    also involve special categories of personal data, such as your racial or ethnic origin (as defined under
    Article 9 of the GDPR). We will process such information, as well as disclose it to competent
    authorities (such as law enforcement bodies), where it is necessary for the following purposes (to the
    extent permissible by applicable law): (i) prevention or detection of an unlawful acts, (ii)
    safeguarding your (or others’) economic well-being.

6. Sharing Information with Third Parties.

We disclose Personal Information in the following cases:

  • With the merchants and operators’ of the Exchanges;
  • With acquiring and card issuing banks;
  • With third-party authentication vendors (such as identity verification vendors) ;
  • With our service providers (such as cloud computing companies);
  • In order to fulfill the purposes stated above, including to satisfy any applicable law, regulation,
    legal process, subpoena or governmental request;
  • In order to respond to claims that any content available on the Service violates the rights of
    third-parties;
  • When we or any of our affiliates is undergoing any change in control, including by means of merger,
    acquisition or purchase of all or substantially all of its assets.

Please note that our businesses, as well as our trusted partners and service providers, are located around the
world. Any information that we collect (including your Personal Information) is stored and processed in various
jurisdictions around the world (including in the United States), for the purposes detailed in this Privacy
Policy. We use best efforts to ensure that your Personal Information is protected in accordance with our privacy
policy, through contractual means (such as by using the contractual clauses approved by the relevant regulators
for data transfer) or other means (such as ensuring that the jurisdiction imposes adequate safeguards for data
protection).

7. Retention of Personal Information.

We will not retain data longer than is necessary to fulfill the purposes for which it was collected or as
required by applicable laws or regulations, such as for KYC and AML purposes. If for any reason you wish to
delete your Personal Information stored with us and identifying to you, please send us an e-mail to legal@an.gold, and we will make reasonable
efforts to address your request.

8. Minors.

To use the Service, you must be over the age of eighteen (18). we do not knowingly collect Personal
Information from children under the age of eighteen (18) and does not wish to do so. We reserve the right to
request proof of age at any stage so that we can verify that minors under the age of eighteen (18) are not using
the Service. In the event that it comes to our knowledge that a person under the age of eighteen (18) is using
the Service, we will prohibit and block such User from accessing the Service and will make all efforts to
promptly delete or effectively anonymize any Personal Information stored with us with regard to such a user.

9. Cookies & Local Storage.

When you access or use the Service, we may use industry-wide technologies such as “cookies” or similar
technologies, which stores certain information on your computer (“Local Storage“) and which
will allow us to enable automatic activation of certain features, and make your Service experience much more
convenient and effortless. We may also use certain third-party tracking technologies. These are a different kind
of cookies, stored on your computer by third parties, rather than by us. This kind of tracking technology is
deployed or used each time you visit the Service, and also when you visit certain websites or applications that
use similar cookies. To learn more please visit our Cookie Policy, available here.

10. Your Rights.

You may contact us at any time at legal@an.gold,
and request:

  • To access (including asking for supplementary information), delete, change or update any Personal
    Information relating to you (for example, if you believe that your personal information is incorrect,
    you may ask to have it corrected or deleted);
  • That we will restrict or cease any further use of your Personal Information;
  • That we will provide the Personal Information you volunteered to us in a machine-readable format.
  • To withdraw your consent to our processing activities (provided that such processing activities rely on
    your consent, and not on a different legal basis);
  • To not be subject to a decision based solely on automated processing, including profiling, which
    produces legal effects concerning you or similarly significantly affects you, except where such
    processing is necessary for the performance of the contract between you and us, or it is based on your
    explicit consent, as provided hereunder.

Please note that these rights are not absolute and requests are subject to any applicable legal requirements,
including legal and ethical reporting or document retention obligations (such as KYC and AML regulations). If
you have any general questions about the Personal Information that we collect about you, how we use it, please
contact us at legal@an.gold.

11. Security.

We take a great care in implementing and maintaining the security of the Service, and our Users’ Personal
Information. The Personal Information is hosted on Amazon Web Services, which provides advanced security
features. We employ industry standard procedures and policies to ensure the safety of its Users’ Personal
Information, and prevent unauthorized use of any such information. In addition, in order to safeguard the
privacy expectation of the Users, we are working on becoming Payment Card Industry Data Security Standards (“PCI DSS”)
certified. Please note that while we take reasonable measures to safeguard your personal data, we cannot fully
guarantee its security.

12. Third Party Websites.

While using the Service you may encounter links to third party websites and/or services. Please be advised that
such third party websites and/or services are independent of us, and may use cookies and other
web-tracking technologies to collect non-personal and/or personal information about you. We assume no
responsibility or liability whatsoever with regard to privacy matters or any other legal matter with respect to
such third party websites and/or services. We encourage you to carefully read the privacy policies and the terms
of use of such third party websites and/or services, as their terms, not ours, will apply to any of your
interactions with such third parties.

13. Changes to the Privacy Policy.

We reserve the right to change this Privacy Policy at any time, so please re-visit this page frequently.
We will provide notice of substantial changes to this Privacy Policy on the Service and/or we will send you an
email regarding such changes to the e-mail address that you volunteered. Such substantial changes will take
effect seven (7) days after such notice was provided on any of the above-mentioned methods. Otherwise, all other
changes to this Privacy Policy are effective as of the stated “Last Revised” date, and your continued use of the
Service after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

14. No Sale of Your Private Information.

We will never sell your personal or private information to anyone. We will never give your personal or private information to anyone, except when ordered by a court or by law enforcement with a valid warrrant.

14. Have any questions?

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send them to our Data
Protection Officer at:
legal@an.gold Attn: Data Protection Officer We will make an effort to reply
within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our
response, you can reach out to the applicable data protection authority:

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