Unicorn Commodity Dmcc (UCD) Formerly known as Valsons Comex DMCC is a licensed direct clearing Member of the DGCX and is regulated by The SCA. Our head office is at: office 1003, Maaya Business Avenue, BB1,JLT, Pobox 336551 Dubai, United Arab Emirates. You can contact us by email at compliance@valsons.ae in relation to any matters pertaining to this Privacy Policy. The websites at https://www.unicorncommodity.com and http://www.valsons.ae (our "Websites") are owned and operated by Unicorn Commodity DMCC (UCD). UCD is a data controller of Personal Information (as defined below) collected on the Website. In this Privacy Policy, references to "we", "us" or "our" means UCD. References to "you" and "your" are to users of our Website, products, and services.

This Privacy Policy describes how we collect, use and otherwise handle "Personal Information" that you provide or make available to us, or that we collect from you, when you use our Website, products, and services, and explains the circumstances in which we may transfer this to others. "Personal Information" is information relating to you, which can be used to personally identify you (either directly or indirectly). Our Privacy Policy must be read together with any other legal notices or terms and conditions which may be available on other pages of our Website. Unless otherwise superseded by alternative terms and conditions (such as in customer or employee contracts), the method in which your Personal Information will be collected, used, distributed and maintained will be in accordance with this Policy.

1. Information that we collect The types of information that we may collect from you, from other individuals and entities you authorize to act on your behalf, or from publicly available sources, will depend on the type of relationship you have with UCD. The information collected from you may include, among other things, your name, email address; address, phone numbers, location, employment information, and location.

Use of Products and Services - Your Personal Information will be used by UCD to provide you with information regarding all the products and services available from UCD. If you are trading or clearing through UCD, UCD may obtain certain Personal Information from you or through your authorized third parties to provide you with the relevant products and services.

Use of our Websites UCD may collect information when you visit our Websites. Some of this information is collected automatically through cookies and when you use any log-in credentials provided to you by UCD. This may include information regarding your use of the Website, including the pages you viewed, and any search terms entered. Your IP address may be used by UCD to provide you with further information regarding UCD. Your information may be combined with Personal Information for UCD to manage and customize the Websites and UCD products and services. Our Websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.

Use of Social Networks - You may be able to connect your personal or business social media accounts to social media accounts maintained by UCD (i.e. Twitter, Linkedin, Facebook, etc.). Your use of this functionality shall be treated as your consent for UCD to obtain the Personal Information available on the social media accounts you link to UCD, in accordance with the privacy policies of those social media sites. Further, our Websites provide sharing buttons that you can click on in order to share content from our Website on social media channels. We do not use these buttons to share your Personal Information with social media providers. When you click on a sharing button the relevant social media provider will gather Personal Information directly from you. Please read the privacy policy of any social media provider with which you intend to share content before clicking on the corresponding sharing button.

Use of UCD Technology Systems - When you use UCD systems, Personal Information may be collected and used, including information regarding your device, operating system, browser, IT infrastructure, application name, vendor, IP address, and country of origin. If you have created accounts on any UCD systems other Personal Information may also be collected, including your name, organization, job title, telephone numbers and email address.

Use of Membership Information -If you seek or have obtained any type of UCD or DCCC Membership then UCD will collect and use all relevant information required to carry out its regulatory due diligence process, including information regarding the name, phone number, titles, email address, passport or tax information, and birthdates of owners and managers. This information may be shared with third-party service providers who provide UCD with software used to conduct regulatory and compliance searches, and with relevant regulatory authorities.

Use of UCD Market Data -UCD may collect Personal Information such as names, titles, phone numbers and emails for its own business and administrative purposes, and as required by certain market data agreements.

Recruitment and Employment -UCD may collect Personal Information from applicants and employees as a part of the recruitment process, to conduct interviews and employee on-boarding. Depending on your status with UCD we may gather and process information including your name, contact details, professional background, references, background checks. We will also obtain and process financial information including your tax status and bank account information required for processing your payroll, and providing you benefits including insurance. You should refer to your employment contract and the relevant HR Policies to understand the information we will obtain, maintain, and process, including information regarding your minor children and beneficiaries in certain circumstances.

2. How we use your Personal Information -

As described in section 1 above, we may use your Personal Information for our business purposes, including but not limited to:
• providing products and services
• record keeping, statistical analysis, internal reporting and research purposes;
• ensuring network and information security;
• notifying you about changes to our services;
• investigating any complaints;
• providing evidence in any dispute or anticipated disputes;
• supporting the operation of our Website;
• detecting and preventing fraud and other criminal offences and for risk management purposes;
• for business and disaster recovery (e.g. to create back-ups);
• for document retention/storage;
• for database management;
• protecting the rights, property, and/or safety of UCD, its personnel and others; and
• ensuring the quality of our products and services.

3. Legal grounds for collection and use of Personal Information We rely upon your consent to process your Personal Information in relation to marketing information and events information we may send to you (where this is made clear to you at the point where you provide your information). In other cases, we process your Personal Information where we need to do so:

• to comply with our legal and regulatory obligations;
• for our legitimate interests in:
• responding to your queries;
• providing services and/or information to you;
• investigating any complaints;
• our internal business purposes, as set out in sections 1 and 2 above.

You can object to processing based on our legitimate interests at any time by contacting us at compliance@valsons.ae. See also "Your Rights" section below.

We consider the risk to your rights of data protection in connection with personal data that we process on the basis of our legitimate interests is not excessive or overly intrusive. We have also put in place protections for your rights by ensuring proper retention periods and security controls.

4. Cookies on the Websites A cookie is a small text file which is placed onto your device when you access our Websites. We use cookies and other online tracking devices to maximize your online experience. The information we obtain from our use of cookies will not usually contain your personal data. Although we may obtain information about your device such as your IP address, your browser and/or other internet log information, this will not, usually, identify you personally. In certain circumstances, we may collect Personal Information about you – but only where you voluntarily provide it (e.g. by completing an online form). In most cases, we will need your consent in order to use cookies. The exception is where the cookie is essential in order for us to provide you with a service you have requested. If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of the Website. For further information about cookies and how to disable them please go to: www.aboutcookies.org or www.allaboutcookies.org.

5.Information from other sources Where permissible under applicable local laws, we may combine information that you have provided to us with other information that we already hold about you and which we have collected for a compatible purpose.

Sharing Information With Third Parties

Some services that we provide require the involvement of third parties. We have carefully selected these third parties and taken steps to ensure that your Personal Information is adequately protected.

1.Sharing with Service Providers When UCD would like to use your Personal Information for a new purpose, we will let you know about this first. We share your Personal Information with our third-party service providers based both inside and outside of the European Economic Area ("EEA") and the United Arab Emirates ("UAE") who we engage to provide support services in relation to our products and services. This includes service providers who, amongst other things:

• support our Websites;
• provide data storage;
• provide IT support services; and
• provide due diligence software to support compliance & legal requirements for on-boarding customers and Members.

All of our service providers are bound by written contracts to process personal data provided to them only for the purpose of providing the specific service to us and to maintain appropriate security measures to protect your Personal Information.

2. Sharing with other third parties We share your Personal Information with:

• our accountants, auditors, lawyers or similar advisers when we ask them to provide us with professional advice;
• any other third party if we are under a duty to disclose or share your Personal Information in order to comply with any legal or regulatory obligation, or to protect the rights, property and/or safety of UCD, our personnel or others;
• any other third party for the purposes of acting in accordance with the requirements of a court, regulator or government agency, for example, complying with a search warrant or court order or acting in accordance with an applicable law or regulation; or
• investors and other relevant third parties in in the event of an actual potential sale or other corporate transaction related to UCD.

International Transfers

The transfer of your Personal Information to third parties may involve your Personal Information being sent outside of the EEA, to locations that may not provide the same level of protection as those where you first provided the information. However, we will only transfer your Personal Information outside of the EEA:

• where the transfer is to a place or by a method or in circumstances that is regarded by the European Commission as providing adequate protection for your Personal Information;
• where we have put in place standard data protection clauses adopted by the European Commission or a relevant data protection authority; or
• where none of the above apply but we are still legally permitted to do so, for example if the transfer is necessary for the establishment, exercise or defense of legal claims.

You can request further detail about the safeguards that we have in place in respect of transfers of Personal Information outside of the EEA and where applicable a copy of the standard data protection clauses that we have in place by contacting us at compliance@valsons.ae.

Storing Personal Information

It is our policy to retain your Personal Information for the length of time required for the specific purpose or purposes for which it was collected. However, we may be obliged to store some Personal Information for a longer time, taking into account factors including:

• legal obligation(s) under applicable law to retain data for a certain period of time;
• statute of limitations under applicable law(s);
• (potential) disputes; and
• guidelines issued by relevant data protection authorities.

Whilst we continue to process your Personal Information, we will ensure that it is treated in accordance with this Privacy Policy. Otherwise, we securely erase your information once this is no longer needed. If you would like to find out how long we keep your Personal Information for a particular purpose you can contact us at compliance@valsons.ae.

Security

We employ appropriate security measures to help protect your Personal Information and guard against access by unauthorized persons. Information storage is on secure computers in a locked and certified information Centre and information is encrypted wherever possible. We undergo periodic reviews of our security policies and procedures to ensure that our systems are secure and protected. However, as the transmission of information via the Internet is not completely secure, we cannot guarantee the security of your information transmitted to our Website.

Confidentiality

We acknowledge that the information you provide may be confidential. We do not sell, rent, distribute or otherwise make Personal Information commercially available to any third party, except that we may share information with our service providers for the purposes set out in this Privacy Policy or with your written consent. We will maintain the confidentiality of and protect your information in accordance with our Privacy Policy and all applicable laws.

YOUR RIGHTS

The following section explains your rights. The various rights are not absolute and each is subject to certain exceptions or qualifications. We will grant your request only to the extent that it follows from our assessment of your request that we are allowed and required to do so under data protection laws. Nothing in this Privacy Policy is intended to provide you with rights beyond or in addition to your rights as a data subject under data protection laws. You have the right to request access to Personal Information that we may process about you. If you wish to exercise this right, you should:

• put your request in writing (an email sent to compliance@valsons.ae. is acceptable);
• include proof of your identity and address (e.g. a copy of your driving license or passport, and a recent utility or credit card bill); and
• specify the Personal Information you want access to.

You have the right to require us to correct any inaccuracies in your Personal Information free of charge. If you wish to exercise this right, you should:

• put your request in writing (an email sent to compliance@valsons.ae. is acceptable);
• provide us with enough information to identify you (for example, your name, include proof of your identity and address (e.g. a copy of your driving license or passport, and a recent utility or credit card bill); and
• specify the information that is incorrect and what it should be replaced with.

You also have the right to ask us to stop processing your personal data for direct marketing purposes. If you wish to exercise this right, you should:

• put your request in writing (an email sent to compliance@valsons.ae. with a header that says ‘Unsubscribe’);
• provide us with enough information to identify you (for example, your name, include proof of your identity and address (e.g. a copy of your driving license or passport, and a recent utility or credit card bill); and
• if your objection is not to direct marketing in general, but to direct marketing by a particular channel (e.g. email or SMS), please specify the channel you are objecting to.

Changes To This Privacy Policy

This version was last updated on: Nov 2019 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.