Effective Date: 2 January 2026

1. WHO WE ARE

This Privacy Policy explains how Oku Markets Limited ("we", "us", "our") collects, uses, and protects your personal information when you use our website and foreign exchange services.

Oku Markets Limited is a UK company providing foreign exchange and currency management services. We are your data controller, which means we are responsible for how your personal information is handled.
We act as the data controller for personal data we collect and use in connection with our services. We also engage certain third-party service providers who act as our data processors and process personal data on our behalf and under our instructions. In some cases, those third parties may act as independent data controllers where they determine the purposes and means of processing for their own obligations (for example, some banks, payment networks, or regulators).

Our contact details:
Email: compliance@okumarkets.com
Address: 1 Armoury Way, London, England, SW18 1TH

If you have concerns about how we handle your data, you can contact the UK's Information Commissioner's Office (ICO) at www.ico.org.uk. However, we'd appreciate the opportunity to address your concerns directly first.

2. WHAT PERSONAL INFORMATION WE COLLECT

We collect personal information to provide our foreign exchange and currency management services. The types of information we may collect include:

• Identity Information: Name, date of birth, nationality; Passport or ID document details; Business role and company information
• Contact Information: Email address, phone number; Business and residential addresses
• Financial Information: Bank account details for currency transactions; Payment card information for our services; Transaction history and trading records; Credit references and financial standing
• Business Information: Company details, trading history; Expected transaction volumes and patterns; Risk management preferences
• Technical Information: IP address, browser type, device information; Website usage data and preferences
• Communications: Records of calls, emails, and other communications; Marketing preferences

We do not collect sensitive personal data such as information about your health, race, religion, or political opinions.

We may also create, use, and share anonymous or aggregated data (for example, statistics about platform usage or FX volumes) for statistical, research, or business purposes. This information does not identify any individual and cannot be used to re-identify you.

3. HOW WE COLLECT YOUR INFORMATION

We collect information when you:

• Register for our services or request quotes
• Complete foreign exchange transactions
• Contact our dealing desk or support teams
• Use our online platform or website
• Provide it during onboarding and compliance checks

We may also receive information from credit reference agencies, payment processors, and other financial institutions to verify your identity and assess transaction risks.

4. WHY WE USE YOUR INFORMATION

We use your personal information for the following purposes:

To Provide Our Services

• Process currency transactions and payments
• Manage your trading accounts and risk positions
• Provide market analysis and trading support
• Deliver customer service and technical support

Legal and Compliance Obligations

• Verify your identity and prevent fraud
• Meet anti-money laundering and counter-terrorism requirements
• Comply with financial services regulations
• Maintain transaction records as required by law

Business Operations

• Assess and manage credit and transaction risks
• Improve our services and platform
• Conduct market research and analysis

Marketing (with your consent)

• Send market updates, product information, and promotional materials
• Provide tailored currency market insights

Automated decision-making and profiling

We do not make decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects about you.
We may use limited profiling to support fraud prevention, anti-money laundering screening, transaction monitoring, and to tailor marketing communications. Such processing is carried out based on our legal obligations and/or our legitimate interests and is subject to human oversight.
Where we conduct profiling for direct marketing, you can object at any time. If we ever carry out solely automated decisions with legal or similarly significant effects, we will inform you in advance and explain your rights to obtain human review, express your point of view, and contest the decision.

5. LEGAL BASIS FOR USING YOUR INFORMATION

We only use your personal information where we have a legal right to do so:
Contract: To provide our foreign exchange services and fulfill our agreements with you
Legal obligation: To comply with financial regulations, anti-money laundering laws, and other legal requirements
Legitimate interests: To operate our business, manage risks, prevent fraud, and improve our services
Consent: For marketing communications and optional services (you can withdraw consent at any time)

Change of purpose: If we need to use your personal information for a new purpose that is not compatible with the purposes set out in this Privacy Policy, we will explain the legal basis for the new use and, where required by law, notify you in advance or ask for your consent.

6. WHO WE SHARE YOUR INFORMATION WITH

We may share your personal information with:

• Service Providers: Payment processors and correspondent banks; Technology providers who support our platform; Professional advisers (lawyers, accountants, auditors); Credit reference agencies and fraud prevention services
• Regulatory and Legal Requirements: Financial regulators and law enforcement agencies; Tax authorities and government bodies; Courts and legal proceedings
• Business Transfers: If we sell or transfer our business, your information may be transferred to the new owners

We do not sell your personal information to third parties for their own marketing purposes.
All third parties must protect your information and use it only for the purposes we specify.

7. INTERNATIONAL TRANSFERS

As a foreign exchange company operating globally, we may transfer your information outside the UK and EU to:
- Correspondent banks and payment partners worldwide
- Technology providers in various countries
- Regulatory authorities in relevant jurisdictions

Where required, we implement appropriate safeguards for international transfers, including reliance on UK adequacy regulations and EU adequacy decisions, the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, and/or the EU Standard Contractual Clauses (SCCs), together with supplementary measures where necessary to protect your data. You can contact us for more information about the safeguards we use.

8. HOW WE PROTECT YOUR INFORMATION

We use appropriate technical and organizational security measures to protect your personal information, including:

• Encryption of sensitive data
• Secure access controls and authentication
• Regular security monitoring and testing
• Staff training on data protection

However, no internet transmission is completely secure. While we work hard to protect your information, we cannot guarantee absolute security.

If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the ICO and, where required, affected individuals without undue delay, in accordance with applicable data protection laws.

9. HOW LONG WE KEEP YOUR INFORMATION

We keep your personal information only as long as necessary for:

• Providing our services and managing our relationship
• Meeting legal and regulatory requirements
• Resolving disputes and protecting our legal interests

Typical retention periods:

• Transaction and trading records: 7 years from the date of the transaction or from closure of your account/relationship.
• AML/KYC onboarding records: 5 years after the end of the business relationship or the date of the last transaction.
• General account and contact details: for the duration of the relationship, then 6 years.
• Communications (calls, emails, chats): 5 years, and up to 7 years in certain regulated circumstances.
• Marketing data and preferences: 3 years from your last interaction with us or until you opt out, whichever is sooner.
• Technical/log data: 12-24 months, subject to our security and compliance needs.

These periods may be extended where required to comply with law or regulatory investigations, or to establish, exercise or defend legal claims. Information may also be retained for limited periods in system backups and archives.

10. YOUR RIGHTS

Under UK data protection law, you have the right to:

• Access: Request copies of your personal information
• Correction: Ask us to correct inaccurate information
• Deletion: Request deletion of your information in certain circumstances
• Restriction: Ask us to limit how we use your information
• Portability: Request your information in a portable format
• Objection: Object to certain uses of your information
• Withdraw consent: For marketing and other consent-based processing
• Complain to the ICO: You can complain to the UK Information Commissioner's Office if you are unhappy with how we have used your data.

To exercise these rights, contact us at compliance@okumarkets.com. We may need to verify your identity before responding.
You will not usually need to pay a fee, though we may charge for excessive or unfounded requests.

ICO contact details:
Website: www.ico.org.uk
Telephone: 0303 123 1113
Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

11. MARKETING COMMUNICATIONS

We may send you information about our services, market updates, and currency insights if:

• You have requested this information, or
• You are an existing customer and the communications relate to our services

You can opt out of marketing communications at any time by:
Clicking unsubscribe links in our emails
Emailing info@okumarkets.com
Contacting your account manager

12. WEBSITE AND COOKIES

Our website uses cookies and similar technologies to improve your experience. For details about what cookies we use and how to manage them, please see our Cookie Policy.
We may include links to third-party websites. We are not responsible for the privacy practices of these sites, so please check their privacy policies.

13. AGE RESTRICTIONS

Our services are only available to individuals aged 18 and over. We do not knowingly collect information from anyone under 18.

14. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. We will notify you of significant changes and post the latest version on our website with the updated date.

15. CONTACT US

For any questions about this Privacy Policy or how we handle your personal information:
Email: compliance@okumarkets.com
Post: Data Protection, Oku Markets Limited, 1 Armoury Way, London, England, SW18 1TH

© 2026 Oku Markets Limited. All rights reserved.