Privacy Policy

DATA PRIVACY POLICY

COWA appreciates your visit to this website and your interest in our services and products. Your privacy is of utmost importance to us. To understand how COWA processes your personal data, please consult the documents outlined below.

WHO WE ARE

COWA has adopted this privacy policy with acknowledgement of the importance ofprotecting the privacy rights and security of the personal information about its visitors. Werecognize that we are expected to provide service in compliance with all applicable laws. Inorder to fulfill our engagement, we require to collect certain personal information.

COWA intends to apply the most restrictive principles and standards with respect to the protection of personal data. All personal data and information provided in relation to our service will be processed lawfully, fairly, transparently, and confidentially.Our official website address is www.cowa.ai , where you will find all relevant information. Ifyou would like to reach us, you can use the following email address: info@cowa.ai.

INFORMATION COLLECTED

COWA, will, depending on the product or service we provide to you (if any), collect and process personal data about you including:

personal details such as your name, identification number, date of birth, KYC documents (including a copy of your national identity card or passport), phone number physical and electronic address, and family details such as the name of your spouse, partner, or children;
inancial information, including payment and transaction records and information relating to your assets (including fixed properties), financial statements, liabilities, taxes, revenues, earnings and investments (including your investment objectives);
where applicable, tax domicile and other tax-related documents and information;
where applicable, professional information about you, such as your job title and work experience;
your knowledge of and experience in investment matters;
details of our interactions with you and the products and services you use;
any records of phone calls between you and COWA;
where applicable, details of your nomination of a mandate;
dentifiers we assign to you, such as your client or account number;
when you access our Website, data transmitted by your browser and automatically recorded by our server, including date and time of the access, name of the accessed file as well as the transmitted data volume and the performance of the access, your web browser, browser language and requesting domain, and IP address (additional data will only be recorded via our Website if their disclosure is made voluntarily, e.g. in the course of a registration or request). When you visit COWA website, that website will contain additional information about how we use your information while you are visiting that website;
in some cases (where permitted by law), special categories of personal data, such as your biometric information, political opinions or affiliations, health information, racial or ethnic origin, religious or philosophical beliefs, and, to the extent legally possible, information relating to criminal convictions or offences. In some cases, we collect this information from public registers (which, depending on the product or service you receive, may include beneficial ownership and other registers), public administration or other third-party sources, such as wealth screening services, credit reference agencies, fraud prevention agencies andother COWA entities.registration or request). When you visit COWA website, that website will contain additional information about how we use your information while you are visiting that website;

If relevant to the products and services we provide to you, we will also collect information about your additional card holders or account holders, business partners (including other shareholders or beneficial owners), dependents or family members, representatives, and agents. Additionally, where you are an institutional or corporate client or investor, we will also collect information about your directors, employees or shareholders. Before providing COWA with this information, you should provide a copy of this notice to those individuals.

ON WHICH LEGAL BASIS AND FOR WHICH PURPOSES WE PROCESS PERSONAL DATA

Legal Basis for processing

Depending on the purpose of the processing activity, the processing of your personal data will be one of the following:

necessary for the legitimate interests of COWA, without unduly affecting your interests or fundamental rights and freedoms (see below);
necessary for taking steps to enter into or executing a contract with you for the services or products you request, or for carrying out our obligations under such a contract, such as when we use your data for some of the purposes,
required to meet our legal or regulatory responsibilities, including when we conduct the checks and make the disclosures to authorities, regulators and government bodies,
in some cases, necessary for the performance of a task carried out in the public interest;
when we use special categories of personal data, necessary for establishing, exercising or defending legal claims or where the processing relates to personal data manifestly in the public domain; and
in limited circumstances, processed with your consent which we obtain from you from time to time (for instance where required by laws), or processed with your explicit consent in the case of special categories of personal data.

Examples of the ‘legitimate interests’ referred to above are:

exercising our rights, including our freedom to conduct a business and right to property;
when we make the disclosures, providing products and services and assuring a consistently high service standard acrossCOWA and its affiliates, and keeping our customers, employees and other stakeholders satisfied.; and
meeting our accountability and regulatory requirements around the world,in each case provided such interests are not overridden by your privacy interests.

Any consent COWA has obtained to process ordinary personal data does not apply for the purposes of the EU General Data Protection Regulation 2016/679 (“EU GDPR”). Instead, for the purposes of the EU GDPR, COWArelies on the lawful grounds of compliance with a legal obligation, contractual necessity or legitimate interests (as specified in this notice) and COWA’s ability to rely on any such consent for the purposes of the EU GDPR is hereby waived or extinguished.

Where the personal data we collect from you is needed to meet our legal or regulatory obligations or enter into an agreement with you, if we cannot collect this personal data there is a possibility we may be unable to onboard you as a client or provide products or services to you (in which case we will inform you accordingly).

Purposes of processing

We always process your personal data for a specific purpose and only process the personal data which is relevant to achieve that purpose. In particular, we process personal data for the following purposes:

client on-boarding processes, including to verify your identity and assess your application (including the need for guarantees or other securitisation tools) if you apply for credit, and to conduct legal and other regulatory compliance checks (for example, to comply with anti-money laundering regulations, and prevent fraud);
providing products and services to you and ensuring their proper execution, for instance by ensuring that we can identify you and make payments to and from your accounts in accordance with your instructions and the product terms;
managing our relationship with you, including communicating with you in relation to the products and services you obtain from us and from our business partners, handling customer service-related queries and complaints, facilitating debt recovery activities, making decisions regarding credit or your identity, tracing your whereabouts, and closing your account (in accordance with applicable law) if it remains dormant and we are unable to contact you after a period of time;
helping us to learn more about you as a customer, the products and services you receive, and other products and services you may be interested in receiving, including profiling based on the processing of your personal data, for instance by looking at the types of products and services that you use from us, how you like to be contacted and so on;
taking steps to improve our products and services and our use of technology, including testing and upgrading of systems and processes, and conducting market research to understand how to improve of our existing products and services or learn about other products and services we can provide;
contacting you for direct marketing purposes about products and services we think will be of interest to you, including those offered by us, COWA and its affiliates, and our other business partners, and facilitating competitions and promotions;
meeting our on-going regulatory and compliance obligations (e.g. laws of the financial sector, antimoney-laundering and tax laws), including in relation to recording and monitoring communications, disclosures to tax authorities, financial service regulators and other regulatory and governmental bodies, and investigating or preventing crime;
ensuring the safety of our customers, employees and other stakeholders;
undertaking transactional and statistical analysis, and related research;
underwriting;
for the COWA’s prudent operational management (including credit and risk management, insurance, audit, systems and products training and similar administrative purposes); and
any other purposes we notify to you from time to time

WHO WE SHARE YOUR DATA WITH

With COWA and its affiliates

We usually share personal data with COWA and its affiliatesin order to ensure a consistently high service standard across our entities, and to provide services and products to you.

Third Parties

When providing products and services to you, we will share personal data with persons acting on your behalf or otherwise involved in the transaction (depending on the type of product or service you receive from us), including, where relevant the following types of companies, when applicable:

a party acquiring interest in, or assuming risk in or in connection with, the transaction (such as an insurer);

companies in which you have an interest in securities where such securities are held by the bank for you;
payment recipients, beneficiaries, account nominees, intermediaries, and correspondent and agent banks;
clearing houses, and clearing or settlement systems; and specialized payment companies or institutions such as SWIFT;
if you hold a credit card with us) credit card associations, and other card payment and platform providers;
market counterparties;
upstream withholding agents;
swap or trade repositories;
stock exchanges;
other financial institutions, credit reference agencies or credit bureaus (for the purposes of obtaining or providing credit references);
any third-party fund manager who provides asset management services to you; and
any introducing broker to whom we provide introductions or referrals.

Service Providers

In some instances, we also share personal data with our suppliers, including COWA affiliates and other business partners who provide services to us, such as IT and hosting providers, marketing providers, communication services and printing providers, debt collection, tracing, debt recovery, fraud prevention, and credit reference agencies, and others. When we do so we take steps to ensure they meet our data security standards, so that your personal data remains secure.

Public and Regulatory Authorities

If required from time to time, we disclose personal data to public authorities, regulators or governmental bodies, including when required by law or regulation, under a code of practice or conduct, or when these authorities or bodies require us to do so.

Other

If our business is sold to another organization or if it is re-organized, personal data will be shared so that you can continue to receive products and services. We will usually also share personal data with prospective purchasers when we consider selling or transferring part or all of a business. We take steps to ensure such potential purchasers keep the data secure.

We may need to disclose personal data to exercise or protect legal rights, including ours and those of our employees or other stakeholders, or in response to requests from individuals or their representatives who seek to protect their legal rights or such rights of others.

HOW LONG WE RETAIN YOUR DATA

We will only retain personal data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements. To help us do this, we apply criteria to determine the appropriate periods for retaining your personal data depending on its purpose, such as proper account maintenance, facilitating client relationship management, and responding to legal claims or regulatory requests.

YOUR RIGHTS OVER YOUR DATA

You have a right to ask COWA to rectify inaccurate personal data we collect and process and the right to request restriction of your personal data pending such a request being considered.

Where we process your personal data on the basis of your consent, you have the right to withdraw that consent at any time. Please also note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

You have a right to ask us to stop processing your personal data, or to request deletion of your personal data – these rights are not absolute (as sometimes there may be overriding interests that require the processing to continue, for example), but we will consider your request and respond to you with the outcome. When personal data are processed for direct marketing purposes, your right to object extends to direct marketing, including profiling to the extent it is related to such marketing. You may object to direct marketingby contacting us at the address: info@cowa.ai

Where we process your personal data on the basis of your consent, or where such processing is necessary for entering into or performing our obligations under a contract with you, you may have the right under applicable data protection laws to request your personal data be transferred to you or to another controller. You have the right to ask COWA for a copy of some or all of the personal data we collect and process about you.

In certain circumstances COWA may process your personal data through automated decision-making, including profiling. Where this takes place, you will be informed of such automated decision-making that uses your personal data, be given information on the logic involved, and be informed of the possible consequences of such processing. In certain circumstances, you can request not to be subject to automated decision-making, including profiling.

You can exercise the rights set out above by contacting us at:info@cowa.ai.

EXERCISING YOUR RIGHTS AND COMPLAINTS

If you are not satisfied with any aspect of the processing of your personal data by COWA, we would like to discuss it with you to understand how we can rectify the issue. You may exercise any of your rights in relation to your personal data by writing to info@cowa.ai. To avoid delay in dealing with your request, please enclose a copy of your passport or identity card.

If you are not satisfied with COWA’s response, you have the right to make a complaint to the data protection authority in the jurisdiction where you live or work, or in the place where you think an issue in relation to your data has arisen.

SECURITY

We have in place appropriate technical and organizational measures to prevent unauthorized or unlawful access to the personal data you have provided to us. As complete data security cannot be guaranteed for communication via e-mails, instant messaging, and similar means of communication, we would recommend sending any particularly confidential information by an alternative secure means.

CHANGE TO PERSONAL DATA

We are committed to keeping your personal data accurate and up to date. Therefore, if your personal data changes, please inform us of the change as soon as possible.

RETENTION PERIODS

In general, COWA will retain personal data for the period of your relationship or contract with COWA plus 10 years, reflecting the length of time for which legal claims may be made following termination of such relationship or contract. An ongoing or anticipated legal or regulatory proceeding may lead to retention beyond this period. COWA must store all electronic correspondence (e-mails, communication via Bloomberg or Reuters, etc.) and evidence of the calls made on business telephones by these employees for a period of two years. The company must also make this information available to its regulators (if applicable) on demand. This applies also to employees identified by a risk based assessment as being highly exposed to information that has relevance to market supervision. COWA also stores all incoming and outgoing business and private communication data (in particular e-mails with attachments, chats, instant messaging) in a separate, protected electronic archive for a period of 10 years.

CHANGE TO THE PRIVACY POLICY

Any amendment or update to this Data Privacy Policy, we will make available to you here: www.cowa.ai

COOKIE NOTICE

COWA takes your privacy seriously. This COWA Website and Cookie Notice (“Notice”) applies to users (“you”) of this and other integrated COWA websites (“COWA Websites”) and contains information that COWA and its affiliates collect(s) through these webpages and what we do with that information. As part of our commitment to protect your “Personal Data” we want to inform you in a transparent manner:

why and how .COWA collects, uses and stores (“processes”) your Personal Data; and
how we protect your Personal Data

WHAT THIS NOTICE COVERS

This Notice applies to any “information” obtained by COWA through your use of COWA Websites and tracking technologies we use It is not applicable to non-integrated COWA websites or any “internet“ websites controlled by third parties not affiliated with COWA that the COWA Websites may link to (“Third Party Sites”). Please review the privacy statements of Third Party Sites as COWA is not responsible for and has no influence on the content or the privacy practices of Third Party Sites. The terms of this Notice are subject to any additional terms of disclaimers or other contractual terms you have entered into with COWA such as client privacy statements or notices, and any applicable laws and regulations.

WHAT TYPE OF INFORMATION IS COLLECTED

We collect the following Information through COWA Websites:

Information that you provide to us, for example:
- Personal details, (e.g. name, gender, address, e-mail address, phone/fax number) on a registration page or if you sign up for an email newsletter;
- User login and subscription data, e.g. login credentials for COWA Websites;
- Other information that you give us by filling in forms, surveys, or by communicating with us, whether face-to-face, by phone, e-mail, online or otherwise.
Information that we collect or generate about you, for example:
- Data our server automatically records when you visit COWA Websites e.g. your IP address, the website from which you visit us, the type of browser software used, the COWA Website pages that you actually visit including the date and the duration of your Authentication information;
- Cookies, pixels, unique identifiers and other similar technologies to collect and process information from different channels and devices, including devices that you use to interact with us, to recognize you, remember your preferences, tailor the content we provide to you. For details on how we use cookies, please refer to the section below;
- Investigations data, e.g. due diligence checks, anti-money laundering checks, content and metadata related to relevant exchanges of information between individuals, organizations;
- Records of correspondence and other communication between us e.g. live chats, instant messages and social media communications;
- Information that we need to support our regulatory obligations e.g. information about transaction details, purpose of payment, counterparty/beneficiary information, detection of suspicious activities.
Information that we collect from other sources, for example:
- Information from third parties or delegated third party service providers e.g. website user information collected through third party application service providers that we have a relationship with, or through cookies, pixels, social plugins, tags and other similar technologies.

PURPOSES OF PROCESSING

We always process your Personal Data for a specific purpose and only process the Personal Data which is relevant to achieve that purpose. In particular, we process Personal Data for the purposes of:

Website Administration. For example, to:
- ensure technical administration, research & development for improving our websites and user administration;
Relationship Management. For example, to:
- assist you in registration to our events or logins;
- allow you to provide feedback;
- keep track of your specified preferences such as language, time zone and timeouts after periods of inactivity;
- respond to any service issues.
Product implementation and execution. For example, to:
- enhance the quality of our products and services and our use of technology.
Engaging in Prospecting and Business Development and / or Protecting and Enhancing the COWAbrand. For example, to:
- contact you in relation to products and services;
- assist with our promotional and marketing efforts;
- help us to develop targeted advertising initiatives (including behavioral advertising) where permitted, for instance ads we consider relevant for (groups of) users on external partner websites and media.
Compliance and Risk Management and / or Crime Prevention, Detection and Investigation. For example, to:
- perform due diligence or anti-money laundering checks on content and metadata.

HOW IS INFORMATION COLLECTED AND STORED

COWA uses tracking technology such as cookies, pixels, unique identifiers or tags (“Tracking Technologies”) to gather information as outlined aboveto understand how visitors use the COWA Website.

Tracking Technology helps us to manage and improve the usability of COWA Websites, for example by detecting whether there has been any contact between your device and us in the past and to identify the most popular sections of the COWA Website. We may also use these Tracking Technologies to check your instructions to us, assess, analyze and improve our service, train our staff.

The “Cookies” link at the bottom of the page gives you more details about COWA’s use of cookies, and lets you control which types of cookies COWA Websites may set on your device (known as your “privacy settings”).

When you save your privacy settings, they should also apply to your future visits to COWA Websites. However, for technical reasons beyond COWA’s control, this cannot be guaranteed. For example, if you reset your browser, delete your cookies or access COWA Websites from another browser or device your privacy settings may be lost. To comply with applicable laws and regulations, in some countries you may be asked to confirm your privacy settings when you first visit a COWA Website. In addition, you might be periodically required to re-confirm your settings.

In many cases you can also control Tracking Technologies using your browser. Please ensure that your browser setting reflects whether you wish to be warned about and/or accept Tracking Technologies where possible. The specific capabilities of your browser and instructions on how to use them can usually be found in the manual or help file of your browser.

Refusing, disabling or deactivating of Tracking Technologies may result in a reduced availability of the services.

HOW DO WE PROTECT YOUR PERSONAL DATA

COWA may disclose your information to its affiliates and their agents and third-party service providers inside or outside your country of residence to perform services for COWA and for the purposes stated above. Our affiliates, agents and third-party service providers who have access to Personal Data obtained through COWA Websites are obliged to respect your privacy, comply with legal obligations and adhere to contractual safeguards. When transferring Personal Data internationally we make sure that we comply with applicable laws and regulations, for example, by entering into agreements which will ensure that the recipients of your information maintain an adequate level of data protection. COWA does not transfer your personal data to other third parties. We may also disclose your information to governmental agencies or entities, regulatory authorities, or other persons in line with any applicable law, regulations, court order or official request, and for the purposes of any guidelines issued by regulatory or other authorities, or similar processes as required by applicable law.

TO WHOM DO WE DISCLOSE YOUR INFORMATION COLLECTED

Please note that if you transfer your information to us through an open network such as the internet, such networks are generally not regarded as a secure environment. Information sent via e.g. the internet (such as to or from the COWA Website or via electronic message) may be accessed by unauthorized third parties, potentially leading to disclosures, changes in content or technical failures. Even if both sender and receiver are located in the same country, information sent via the internet may be transmitted across international borders and be forwarded to a country with a lower data protection level than the one in your country of residence. Please note that we accept no responsibility or liability for the security of your information whilst in transit over the internet to COWA. In order to protect your privacy we would like to kindly remind you that you may choose other means of communication with COWA, where you deem it appropriate.

HOW INFORMATION FROM INDIVIDUALS UNDER THE AGE OF 18 IS DEALT WITH

COWA Websites do not seek to collect Personal Data from individuals under the age of 18. Children should obtain parental or legal guardian consent as per the age threshold established by each country (which, for example in the EU, can be between 13 and 16 years depending on the Members State).

CONTACT

If you are not satisfied with any aspect of the processing of your Personal Data by COWA, please let us know and we will investigate your concern by contacting us at: info@cowa.ai

CHANGE TO THIS NOTICE

Any amendment or update to this Notice will be made available to you viaour website: www.cowa.ai.