Privacy Policy

THIS PRIVACY POLICY (PRIVACY POLICY) IS A POLICY OF ALFARDAN EXCHANGE LLC (AFX)

It is a legally binding document between you as a user (referred to in this Privacy Policy as ‘you‘ or ‘user‘) and Alfardan Exchange (referred to as ‘AFX‘, ‘we‘, ‘us‘, ‘our’).

The Privacy Policy is the policy adopted by Alfardan Exchange and which sets out and
explains how we treat your personal data and protect your privacy when you engage with us
and use our website in compliance with Qatar’s Law No.13 of 2016 concerning the
Protection of Personal Data (Privacy Law).

This website (www.alfardanexchange.com.qa) is brought to you by Alfardan Exchange (a
company incorporated under the laws of the State of Qatar with Commercial Registration
Number: 3950 and registered address of P.O. Box : 339 Doha, Qatar).

Under our Privacy Policy, and by providing us with your information or by making use of the
facilities provided by or on this Website, you consent to the collection, storage, processing
and transfer of any or all of your personal information and non-personal information by us as
specified under this Privacy Policy and subject to its terms and conditions.

Please read this Privacy Policy carefully. This Privacy Policy shall be read together with the
respective terms of use or other terms and conditions of AFX as set out elsewhere on this
Website.

By visiting this Website, you agree: (i) that you have read and understood this
Privacy Policy in its entirety; (ii) that, without reservation and to the extent permissible under
applicable laws and regulations in the State of Qatar, you consent, accept and agree to be
bound by the terms and conditions of this Privacy Policy; and (iii) that you understand that
this Privacy Policy shall be read in conjunction with the terms of use or other terms and
conditions of AFX and other specified commercial partners (Terms) as set out elsewhere on
this Website with (i) to (iii) together the Undertakings (Undertakings).

If you do not agree to the Undertakings, please stop using, do not use or access our Website.
The terms of this Privacy Policy will be effective upon your acceptance of the same (directly
or indirectly in electronic form, by clicking on the “I agree” tab or by use of the Website) and
will govern the relationship between you and us for your use of the Website.

1. Our Privacy Policy

• Our commitment to the privacy of your personal data

At Alfardan Exchange, your privacy and the security of the personal data that you provide to
us is of the utmost importance to us. We are committed to safeguarding the privacy of your
personal data and the information that you provide and we take all necessary precautions to
ensure its security. We will also provide you with information and transparency with regard
to how we process and use such personal data.

We have a legitimate purpose in using your information where this is necessary and
appropriate to provide comprehensive and optimal services to you as our valued customer.
Under our Privacy Policy, and by providing us with your information or by making use of the
facilities provided by or on this Website , you consent to the collection, storage, processing
and transfer of any or all of your personal information and non-personal information by us as
specified under this Privacy Policy and subject to its terms and conditions.

• How we collect your personal data and information

AFX is into money transfer, foreign currency exchange and bullion trading business that is authorized to operate in Qatar and to undertake
activities under its commercial license. We will process your personal data in the context of
that legitimate purpose. Such purpose will include processing personal data so we can:
(a) provide you with comprehensive and optimal products and services in connection with
our business;
(b) improve our product and service offerings to you; and
(c) ensure you are made aware of and we can make available to you products and services
that may be of interest.

When you use our Website, we collect and store your personal data and information, which is
provided by you from time to time. Our primary goal in doing so is to provide you a safe,
efficient, smooth and customized experience.

This allows us to provide services and features that most likely meet your needs, and to
customize our Website to make your experience safer and easier. More importantly, while
doing so we collect personal information from you that we consider necessary for achieving
this legitimate purpose.

In general, you can browse the Website without telling us who you are or revealing any
personal information about yourself. Once you give us your personal information, you are not
anonymous to us. Where possible, we indicate which fields are required and which fields are
optional. You always have the option to not provide information by choosing not to use a
particular service or feature on the Website. We may automatically track certain information
about you based upon your behavior on our Website. We use this information to do internal
research on our users’ demographics, interests and behavior to better understand, protect and
serve our users. This information is compiled and analyzed on an aggregated basis. This
information may include, but not be limited to, the URL that you just came from (whether
this URL is on our Website or not), which URL you next go to (whether this URL is on our
Website or not), Your computer browser information and your IP address.

• How we use your personal data and information

We collect personally identifiable data (including, but not limited to, email addresses, names,
phone numbers and credit card/ debit card / other payment instrument details) from you when
you set up an account with us. While you can browse some sections of our Website without
being a registered member, certain activities may require registration.
We do use your contact information to send you offers based on your interests.

We use personal information to provide the services you request. To the extent we use your
personal information to market to you, we will provide you the ability to opt-out of such uses.

We use your personal information for a range of matters including in order to resolve
problems and disputes, help promote a safe service, collect money, measure consumer
interest in products and services, inform you about online and offline offers, products,
services, updates, customize your experience, detect and protect us against error, fraud and
other criminal activity; enforce our terms and conditions and as otherwise may be described
to you at the time of collection.

In our efforts to continually improve our product and service offerings, we collect and
analyze demographic and profile data about our users’ activity on our Website.

We identify and use your IP address to help diagnose problems with our server and to
administer our Website. Your IP address is also used to help identify you and to gather broad
demographic information. We will occasionally ask you to complete optional online surveys.
These surveys may ask you for contact information and demographic information (like age or
income level). We use this data to tailor your experience at our Website, providing you with
content that we think you might be interested in and to display content according to your
preferences.

• Sharing your personal information with third parties

We may share personal information with other AFX companies, contractors and service
providers (Partner/s) which support us in the delivery of our products and services to you, so
that we can optimize the products and services we provide and make available to you. This
personal data cannot be used by the Partners to market their own services. We will require the
Partner to take steps to ensure that your personal data and information is kept secure and used
in accordance with this Privacy Policy. However, we shall not be liable for any unauthorized
use of your personal information by a Partner. The disclosure to third parties may be required
for us to provide you access to any of our products and services, to comply with our legal
obligations, to enforce any applicable user agreements, to facilitate our marketing and
advertising activities or to prevent, detect, mitigate and investigate fraudulent or illegal
activities related to any of our services. We do not disclose your personal information to third
parties and Partners for their marketing and advertising purposes without your explicit
consent.

This Privacy Policy only applies to personal information collected on the Website. Although
the Website may provide links to websites of third parties, such as cloud service providers,
this Privacy Policy does not apply to any other website that you connect to from the Website.

We are not responsible for the content or practices of websites operated by third parties that
are linked to or from the Website.

We may share personal information with our other corporate entities, affiliates and Partners.

These entities, partners and affiliates may market to you as a result of such sharing provided
they clearly identify themselves (including setting out their contact details) and indicate that
they are sending a marketing message in any communications to you unless you explicitly
opt-out or withdraw your consent using the contact details which should be provided to you
by such entities, Partners and affiliates.

We may send marketing information to you in relation to promotions that we run from time
to time or service offerings we consider may be of interest to you. You can ask us not to
process your personal information for marketing purposes by checking certain boxes on the
forms used to collect your information or by updating your marketing preferences in your
User Account. You can also exercise the right at any time by contacting us at the following
address: privacy@alfardan.com.qa.

As indicated earlier, Partners will not be permitted to market to you directly in connection
with other services they offer. In the event that you receive any such marketing
communication that you have not specifically requested you should let us know immediately.

We may disclose your personal information to other member companies of the AFX. We may
also disclose your personal information to third parties in the following circumstances:
(a) in order to provide services requested or purchased by you;
(b) to any Partner;
(c) where those third parties assist us in supplying our services to you or perform certain
functions on our behalf, including IT support services or professional services;
(d) in the event of a sale, merger, liquidation, receivership or transfer of assets of AFX or one
of our affiliated companies, to the prospective buyer of the business and their professional
advisers; and
(e) if required to do so by law, a court order or by a regulatory authority of competent
jurisdiction or if we believe that such disclosure is necessary, to protect, defend or enforce
our rights. This includes exchanging information with other companies and organizations for
the purposes of fraud protection and credit risk reduction.

Please note that in order to cooperate with governmental requests, court orders, or to protect
other users or our systems, we reserve the right to disclose any information we consider
necessary or appropriate, including your user profile information (ie name, email address,
etc.), IP address and traffic information, usage history, and content submitted to the Website.

• How we use ‘Cookies’

We use data collection devices such as “cookies” on certain pages of the Website to help
analyze our web page flow, measure promotional effectiveness, and promote trust and safety.

A “cookie” is a small piece of information stored by a web server on a web browser so it can
be later read back from that browser. Cookies are useful for enabling the browser to
remember information specific to a given user. We place both permanent and temporary
cookies in your computer’s hard drive. The cookies do not contain any of your personally
identifiable information .We offer certain features that are only available through the use of a
“cookie”. We also use cookies to allow you to enter your password less frequently during a
session. Cookies can also help us provide information that is targeted to your interests. Most
cookies are “session cookies,” meaning that they are automatically deleted from your hard
drive at the end of a session. You are always free to decline our cookies if your browser
permits, although in that case you may not be able to use certain features on the Website and
you may be required to re-enter your password more frequently during a session.

Additionally, you may encounter “cookies” or other similar devices on certain pages of the
Website that are placed by third parties. We do not control the use of cookies by third parties.

If you send us personal correspondence, such as emails or letters, or if other users or third
parties send us correspondence about your activities or postings on the Website, we may
collect such information into a file specific to you.

We collect personally identifiable data (including, but not limited to, email addresses, names,
phone numbers and credit card/ debit card / other payment instrument details) from you when
you set up an account with us. While you can browse some sections of our Website without
being a registered member, certain activities may require registration. We do use your contact
information to send you offers based on your interests.

2. Links to Other Sites

Our Website links to other websites that may collect personally identifiable information about
you. AFX is not responsible for the privacy practices or the content of those linked websites.

3. Security Precautions

Our Website has stringent security measures in place to protect the loss, misuse, and
alteration of the information under our control. Whenever you change or access your account
information, we offer the use of a secure server. Once your information is in our possession
we adhere to strict security guidelines, protecting it against unauthorized access.
The transmission of information via the Internet is not completely secure. We will do our best
to protect your personal information while it is in our possession. However, we cannot
guarantee the security of your data transmitted online or over the Website.

We recognize industry standards and employ security safeguards to protect your personal
data from unauthorized access and misuse. All information you provide to us is stored on
secure servers. Any payment transactions will be protected and safeguarded by encryption by
using secure socket layer SSL encryption and certificates.

4. Access to your Personal Data

You can request access to your personal data. This will enable you to receive a copy of the
personal data we hold about you.

You can also request correction of the personal data that we hold about you. This enables you
to have any incomplete or inaccurate data we hold about you corrected, although we may
need to verify the accuracy of the new data you provide to us.

You can request erasure of your personal data. This enables you to ask us to delete or remove
personal data where there is no good reason for us continuing to process it. Please note,
however, that we may not always be able to comply with your request of erasure for specific
legal reasons which will be notified to you, if applicable, at the time of your request.

You may withdraw consent at any time where we are relying on consent to process your
personal data. However, this will not affect the lawfulness of any processing carried out
before you withdraw your consent.

If you withdraw your consent, we may not be able to provide certain products or services to
you. We will advise you if this is the case at the time you withdraw your consent.

5. Choice and Opt-Out of Promotions and Services

By consenting to this Privacy Policy and using this Website, you consent to receiving
electronic communications of a personal commercial nature as set out in this Privacy Policy
and the Website.

We provide all users with the opportunity to opt-out of receiving non-essential (promotional,
marketing-related) communications from us on behalf of our Partners, and from us in general,
after setting up an account.

If you want to remove your contact information from all AFX and third party and Partner lists
and newsletters and want to opt-out of and/or withdraw your consent to receiving any
advertising or marketing materials, please unsubscribe.

6. Meeting Qatar Legal Requirements and Your Rights

This Privacy Policy is provided to you in compliance with the Privacy Law.

You have a number of rights under the Privacy Law with regard to how we handle and
process your personal data and information. These include your rights to:
(a) withdraw any consent given to us for processing at any time;
(b) be notified about the personal data that is being processed about you and the purpose for
which it is processed;
(c) be notified of any disclosure of inaccurate personal data about you;
(d) receive a copy of your personal data – we may charge a service fee for this;
(e) raise objection and ask us to erase personal data if it is no longer necessary in relation to
the purposes for which it was collected or if it is excessive or if the processing is
discriminatory, prejudicial or unlawful or if the purpose for which the personal data was
processed no longer exists and there is no longer any reason to have it;
(f) request correction of your personal data – you should provide evidence to help us support
you with such a request;
(g) complain to the competent authority in Qatar established under the Privacy Law to
administer and oversee the operation of and compliance with the Privacy Law, where you are
concerned that we may have not complied with the Privacy Law or any of its implementing
requirements.

Under the Privacy Law, we cannot send you any electronic communications for the purpose
of direct marketing without first obtaining your consent.

7. Software Disclaimer

The software downloads from this Website have been thoroughly scanned and tested at all
stages of production, but, as with all new software, we still recommend that you run a virus
checker before use. We also recommend that you have an up-to-date backup of your hard
disk before using the software. We cannot accept responsibility for any disruption, damage
and/or loss of data on your data or computer system that may occur while using the software.
Consult your network administrator before installing any software on a networked computer.

We do not make any warranty that the functionality of the Website will be uninterrupted or
error free.

8. General

Any dispute relating to enforcement, interpretation or application of this Privacy Policy shall
be governed by and construed in accordance with the laws of the State of Qatar. Any dispute
arising out of or in connection with this Privacy Policy shall be dealt with through the Courts
of the State of Qatar to the exclusion of all others.

If any of terms and conditions of this Privacy Policy should be determined to be illegal,
invalid or otherwise unenforceable by reason of any applicable laws or regulations; such
provisions shall be severed and deleted from this Privacy Policy. To the extent reasonably
possible, all other terms and conditions of this Privacy Policy shall remain in full force and
continue to be binding and enforceable.

No ideas, material, computer code, information or other communication you submit or post to
the Website will be considered confidential or proprietary. All such material becomes the
exclusive property of AFX which is entitled to use such material for any purpose without
restriction or compensation.

You are prohibited from posting or transmitting to or from the Website any unlawful,
infringing, threatening, libelous, defamatory, obscene or offensive material or any other
material that would violate any applicable laws and regulations and we reserve the right to
delete such material without giving any notice. We also reserve the right, at our sole
discretion and without providing any explanation, to block any user from entering the
Website permanently. Views expressed or comments offered by the users shall be personal in
nature of the users and we shall not have any responsibility whatsoever in this regard.

To the fullest extent permitted by applicable law or regulations, neither AFX nor any other
third party, service provider or Partner acting on behalf of or in conjunction with AFX, nor
any of the respective affiliates, group companies, subsidiaries or holding companies of either
AFX or any authorized contractor, partner or service provider acting on behalf of or in
conjunction with AFX (Protected Companies) nor any of the respective owners, shareholders,
directors, officers, employees, agents, consultants or representatives of any Protected
Companies (Protected Parties) shall be responsible for any proceedings, claims, liabilities,
costs, fees (including attorney fees), expenses, delays, losses, penalties or other damages
(howsoever arising) caused to you or any other third party arising out of or in connection with
this Privacy Policy.

9. Contact

Should you have any questions or queries regarding this Privacy Policy, the relevant contact
details to use for AFX are:
Attention: Information Security Department – ISD
Address P.O. Box 339 , Doha, Qatar
Email: privacy@alfardan.com.qa

10. Changes to this Privacy Policy

Any changes we may make to this Privacy Policy in the future will be posted on the Website
and, where appropriate, notified to you. By continuing to use the Website you will be deemed
to accept the changes to this Privacy Policy