At 1ero Trader LLC (1ero Trader), we understand that the confidentiality and security of the personal information ("Personal Information") you share with us is important. Because of this, we are committed to protect the privacy of your Personal Information. For that reason, we have developed specific policies and practices designed to protect the privacy of your Personal Information. By opening an account with 1ero Trader or by using the tools and applications available through 1ero Trader, you consent to the collection and use of your Personal Information in accordance with this privacy policy ("Privacy Policy" or "Policy"). We encourage you to read this Privacy Policy carefully.

This Privacy Policy is intended to summarize 1ero Trader LLC's data protection practices generally and to advise our clients, prospective clients, website visitors and other third parties of our privacy policies that may be applicable to them. This policy specifically addresses those who provide personal information to 1ero Trader or who visit or use 1ero Trader's website, trading platform, software application and social media sites.

Who is responsible for your personal information?
1ero Trader is responsible for the personal information we may collect in the manner set out below. Specifically, your Personal Information will be controlled by the Entity that is providing tools or a communication to you. However, in some cases your Personal Information will be controlled by more than one 1ero Trader Entity. How do we collect your Personal Information and what Personal Information do we collect?
1ero Trader collects and processes your Personal Information. This may include, among other things, information:
• provided during the 1ero Trader account opening application process or during the use of any of the applications on our website. This information is primarily your full name, address, email address, telephone number, date of birth, gender, investment objectives, etc.
• acquired because of the transactions you perform through 1ero Trader's.
• received from consumer reporting agencies.
• collected through Internet cookies (for more information on our use of cookies, please see our Cookie Policy).

For what purposes will we use your personal information?
We may use your personal information for the following purposes ("Permitted Purposes"): • To provide services to you pursuant to any agreement you may have with us directly or indirectly, for our own administrative, record keeping and compliance procedures.
• To provide you with brokerage and other services available on our platforms, and/or to fulfill any requests or inquiries you may have.
• To pursue legitimate interests, including to conduct, monitor and analyze our business or operations, including the activities set forth in this Privacy Policy.
• To enforce or apply any agreements and/or to protect our property or rights (or those of others) and to defend any potential claims.
• To carry out our recruitment processes.
• To respond to your requests for information and to carry out a follow up afterwards to see if we can provide further assistance.
• To contact you (unless you tell us that you prefer us not to do so) regarding features and functionalities that may be of your interest.
• To enter into or perform agreements of various kinds.
• To carry out the supervision by us or anyone else on our behalf by using various methods, including (i) the use of automated "smart" monitoring tools; or (ii) through random monitoring of systems, for example, systematically through electronic communications recording tools; (iii) targeted monitoring of systems, e.g., in connection with investigations, regulatory requests, access requests by a person, litigation, arbitration or mediation or; (iv) data tracking, aggregation and analytics tools that pull data from various disparate data sources to establish linkages and/or detect patterns of behavior, interactions or preferences for analysis (including predictive analytics); and/or (v) the use of other similar monitoring technology that may be available from time to time.
• For statistical purposes and to conduct market research and analysis, as well as to develop and improve our products and services.
• To prevent and detect money laundering, terrorism, fraud or other crimes and/or abuse of our services.
• To comply with any legal, regulatory, or good practice requirements from the competent authorities.
• To comply with applicable laws in any country.
We may also process your Personal Data for the following purposes, subject to obtaining your express consent where legally required, in accordance with your preferences:
• To communicate with you through the channels you have approved to keep you up to date with the latest news, announcements, and other information about our services and products;
• To conduct customer surveys, marketing campaigns, market analysis or promotional activities;
• To collect information about your preferences to create a user profile that allows to personalize and enhance the quality of our communication and interaction with you. Where required by law, with respect to marketing-related communication, we will only provide you with such information after you have opted-in or had an opportunity to opt-out, and we will also give you the opportunity to opt-out at any time if you no longer wish to receive marketing-related communications from us. We like to keep our clients, staff and other interested parties informed about company news, including news related to 1ero Trader that we believe are of your interest. If you do not wish to receive publications or details of events or seminars that we feel may be of your interest, please let us know via this link: info@1erotrader.com. Where required by law, we will not use your personal data to make automated decisions affecting you or to create profiles other than those described above. Depending on the permitted purposes we use for your personal information, we may process your personal information for one or more of the following lawful reasons:
• Because the processing is necessary for the performance of your instruction or other contract with you or to take steps prior to entered into such contract.
• To comply with our legal obligations.
• Because the processing is necessary for the purposes of our legitimate interests or those of any third party recipient of your personal data, provided that such interests are not overridden by your interests or fundamental rights and freedoms.
• Because we are obliged to do so in accordance with a decision of a competent authority.
In addition, processing may be based on your consent where we have expressly requested it and you have expressly given it to us.
With whom we share your personal information and under what circumstances We may share your Personal Information in the following circumstances:
• We may share your Personal Information among 1ero Trader entities on a confidential basis as permitted by applicable law or as necessary to provide quality tools and for administrative, billing, and other business purposes.
• We may engage service providers inside or outside of 1ero Trader, domestically or abroad, to process Personal Information for the Permitted Purposes on our behalf and account and in accordance with our instructions.
• We may share your personal information with companies and authorities related to criminal proceedings and investigations, such as criminal, financial authorities and institutions, regulatory bodies, banks, etc.
• We may disclose information about you to any intermediary in the financial system, where the disclosure is for the reasonable purpose of carrying out, managing, or reporting transactions in connection with our platform or establishing a relationship with a view to such transactions.
• We may share your personal information with third parties to assist us in carrying out our recruitment processes.
• In accordance with applicable law, we may share your Personal Information with courts of law, law enforcement authorities, regulators or lawyers or other parties in connection with any legal proceedings or alternative dispute resolution process.
• We may also use aggregated Personal Information and statistics for the purpose of monitoring the website use to help us develop our website.
We will only disclose your Personal Information when you give us permission to do so, when we are permitted or required to do so by law, or when we are requested to do so by a competent authority.
Personal Information about others that you provide to us If you provide us with Personal Information about another person, you should ensure that you have the right to disclose that Personal Information to us for processing as described in this Privacy Policy.
Maintaining the security of your Personal Information To the extent required by law, we will take appropriate technical and organizational measures to maintain the confidentiality and security of your Personal Information in accordance with our internal procedures covering the storage, disclosure and access to Personal Information. Personal information may be stored in our information technology systems, those of our contractors or in paper files.
Updating Your Personal Information If any of the Personal Information you have provided to us changes or if you wish to cancel any request you have made to us, you need to let us know by contacting our Customer Service via the 1ero Trader website at https://primerotrader.com We will not be liable for any loss arising from any inaccurate, unauthentic, deficient or incomplete personal information you provide to us.
How long do we keep your personal information?
Personal information is retained for as long as necessary to comply with legal, regulatory and business requirements, and these periods may be extended if we are required to retain your personal information in connection with any legal proceeding or alternative dispute resolution process.
ARCO Rights
You have the right to know what personal information we hold about you, what we use it for and the terms of our use of it (Access). Likewise, it is your right to request the correction of your personal information in case it is outdated, inaccurate or incomplete (Rectification); that we remove it from our records or databases when you consider that it is not being used properly (Cancellation); as well as to oppose the use of your personal information for specific purposes (Opposition). These rights are known as ARCO rights.
To exercise any of the ARCO rights, you must submit the respective request in writing addressed to 1ero Trader or by email info@1erotrader.com.
You may contact the Personal Data Department of 1ero Trader, to solve doubts or comments regarding your procedure(s), as well as to process the ARCO rights requests. For this purpose or to obtain more information regarding the exercise of your ARCO rights, please refer to our Privacy Notice.

Updates to this Privacy Policy
This Privacy Policy was last updated on November 3, 2022. We reserve the right to update and modify this Privacy Policy at any time we deem appropriate. In the event we make a change, we will post the modified Privacy Policy on our website or otherwise publish it. The changes will be effective as soon as they are posted on our website.

How to Contact Us
If you have any questions regarding this Policy, please contact 1ero Trader's Data Protection Department at info@1erotrader.com (email) or contact 1ero Trader Customer Service through our website at https://1erotrader.com.