LAST UPDATED 29 AUGUST 2025

www.babaoption.com

support@babaoption.com

Contents

1. General Information...................................................................................................................................................................................3

2. Personal Information:Types and Methods of Collection..........................................................................................................4

3. Cookies............................................................................................................................................................................................................5

4. Types of Data Acquired from Users’ Devices................................................................................................................................. 5

5. Basis and Purposes of Personal Data Processing.......................................................................................................................5

6. Storing of Personal Data and Retention Period.............................................................................................................................6

7. Third - Party Disclosure...........................................................................................................................................................................6

8. Changes in This Policy.............................................................................................................................................................................7

Terms and Conditions

Last updated 25 AUGUST 2025

This privacypolicy (the “Policy“) explains how the BABAgroup (collectively “BABA“, “we” or “us” and each member

of the BABA group for whose services you registered, the “BABA Entity“) collects, uses and discloses personal

information through its websites, mobile applications,and other online productsand services that link to this

Policy, including any of the products and services detailed in the following paragraph (collectively, the “Services“)

or when you otherwise interact with us.

1. General Information

The collection and use of personal information constitute an integral part of our daily business activity, whereby

we intend to provide the best services and products to you, including potential clients.

The present Privacy Policy (“Policy”) is an integral part of the public documents’ set, which is aimed to establish

and regulate our approach in relation to the application of aggregated your personal information while providing

services to you. The Policy is revised periodically to ensure that all newly appeared legislative changes,

technological solutions, changes related to business practice are comprehensively incorporated in a proper way

and maintain the most up-to-date character.

Since the Policy has been adopted as a part of our set of documents, theacceptance of this Policy is

indispensable for the provision of our services. If a potential or actual client refuses to give consent to the terms

of this Policy, it shall immediately lead to the cessation of all services and termination of other contractual

arrangements between you and us.

This Policy applies a range of privacy-related terms, among others the listed definitions are:

Consentshall mean intentional, unambiguous and freely given permission by you to process the

data relating to you;

Encryptionshall mean the method whereby the data (irrespectively of its form and format) is

converted to an encoded version which can be subsequently decoded by the persons having access

and decryption key;

Processingshall mean anaction or a set of actions, performed on personal data or personal

information whether or not by automated means;

Third partyshall mean any legal or natural person, public authority, body or agencywhich is

authorized to request access to or process personal data under our authority or in cases prescribed

by law;

Personal Data or Personal Informationshall mean any information related to an identified or

identifiable client, i.e., you;

Terms and Conditions

Last updated 25 AUGUST 2025

Secure Sockets Layer (“SSL”)shall mean a cryptographically secured protocol, used for secure

connection and transmission of data;

PCI Data Security Standard (“PCI”)shall mean a self-regulatory system that provides an enforceable

security standard for payment card data which also covers a compulsory application of the security

assessments and violations’ detection.

2. Personal Information: Types and Methods of Collection

Your personal information is collected in two possible ways, namely manual and via automated means. The data

collected manually means that you take all reasonable steps in the provision of the particular information or a

document.

This Policy sets the following types of personal data to be acquired from you prior to and in the course of business

relations between you and us:

Full name as provided in passport or other ID, date of birth and residence address;

Contact details such as emailing address, telephone number, fax of any other;

Information regarding your income, including source of funds, financial assets and liabilities, bank

account information;

Trading performance, knowledge and experience;

Identity verification documents such as Passport, ID Card or Driving License;

Residence verification documents such as utility bill, residence certificate or other; and

Preferences on which of our services and products you are interested in.

The Policy sets the following information that is acquired via the automated means:

IP-address;

Network system;

Type of operational system; and

Types and settings of browser;

By general rule, information collected via automated means should not be considered as able to identify you either

directly or indirectly. The list of information requested from you should not be considered exhaustive. We preserve

the right to request additional data especially in cases when it is necessary to ensure compliance with the

regulations of existing legislation.

Terms and Conditions

Last updated 25 AUGUST 2025

3. Cookies

Cookies are small files stored on a computer or other device and used by the web server for keeping track of your

browser activities, including delivering individually tailored requests into a session. This means that cookies are

used for assessing advertisements and promotions as well as evaluating your interests in services and products

provided by us.

Cookies foresee the possibility of choice whether to accept all, restrict to limited range or withdraw from them.

However, you should note that partial or full restriction of cookies would lead to the impossibility to access or use

certain parts of our website or its features.

4.Types of Data Acquired from Users’ Devices

Web Bugs (or web beacon, pixel tag, clear GIF) which constitute a little graphic image that is usually delivered via

web-browser or an email and used for the tracking ofemails’ delivery, web-pageviewing and other statistical

information.

Device information which is obtained at the moment of your access to the website. The recognition of your device

is important for delivering the most appropriate version of the website.

Log information which is necessary for the tracking of website user’s activity and ensure the diminishing any

potential inconsistencies.

Location information, through the identification of the IP address in order to be able to localize the content for a

particular country that you see on our website.

5. Basis and Purposes of Personal Data Processing

Statutory compliance:In order to provide our services, we are subject to compliance with a range of legislative

provisions, in particular those regulating the prevention of money laundering and terrorism financing, financial

services provision, taxation, corporate and other branches of law.

Performance of contractual obligations:We process personal data to accomplish onboarding, Know Your

Customer (KYC) and Customer Due Diligence (CDD) procedures and provide our services and products.

Formation of a profile and assessment of appropriateness: We need to process your personal information at the

moment of account opening. Subsequently, on a periodic basis, we perform an assessment to provide only

appropriate services to you.

Terms and Conditions

Last updated 25 AUGUST 2025

Marketing purposes:Personal data processed by us may be used to send marketing communications to you,

ensuring you are informed about the latest news, changes, and improvements related to our services. You may

withdraw from marketing communications; however, this does not cover cases where we intend to deliver legally

required information.

Improvements to services and products: We may use information acquired from your activity and use of services

to monitor and improve the quality of our services.

Development and marketing of new services and products: Information may be used for creation and promotion

of new services.

Legitimate interests:We have to protect and ensure the efficiency of our legitimate interests, including internal

business management, risk management, records keeping, security measures, ITsystem operation, marketing

purposes, and communication with you on legal matters. We commit that the use of personal information for

legitimate interests will not violate the security of your data.

6. Storing of Personal Data and Retention Period

We undertake all reasonable efforts to ensure comprehensive security of personal data against external

vulnerabilities. Secure Sockets Layer (SSL) encryption technology is used to enhance protection of information.

Application of PCI scanning measures, Transport Layer encryption, and AES algorithm in Application layer with

256-bit key length reduce risks associated with external threats related to data stored on credit cards.

Complex authentication systems and access control mechanisms avoid unauthorized access to systems and

data, which are kept on different internal systems and secured servers.

If the business relationship is terminated, we may be obliged to retain your personal information for a certain

period, as prescribed by law, which may vary in duration and scope.

7.Third - Party Disclosure

We shall not disclose your personal data to any third party. However, the following cases exempt us from any

liability for disclosure or sharing of personal information:

In accordance with applicable laws, regulations, prescriptions, or other binding instruments, we may

disclose personal information to the required extent, either on our own initiative or upon legitimate

request by state authorities, law enforcement agencies, judicial orders, or regulatory bodies; or

Terms and Conditions

Last updated 25 AUGUST 2025

Disclosure to third parties performing specific functions on behalf of us, actingunder our

authorization, following ourcompliance procedures, and maintaining adequate personal data

security.

Additionally, inthe course of providing services to you, we may share your personal data with our affiliates or

group entities. Such transfers may occur after you complete the sign-up process, particularly during the account

activation stage, for the purposes of account management and service provision.

These affiliated entities are contractually bound to adhere to the same data protection standards set forth in this

data.

8. Changes in This Policy

This Policy is subject to timely revision to account for new laws, technologies, changes to our operations and

practices, and to ensure it corresponds to the changingenvironment. You will be notified about these revisions

through available communication means.