Privacy Policy.

Personal Information You Provide To Us

In Short: We collect personal information that you voluntarily provide to us.

We collect personal information that you voluntarily provide when you register for our Services, express an interest in our products or services, participate in activities on our platform, or otherwise contact us.

Personal Information Provided by You. The personal information we collect depends on the context of your interactions with us and may include:

• Full name
• Phone numbers
• Email addresses
• Business name and role

Sensitive Information. Where necessary and with your consent (or as otherwise permitted by applicable law), we may process the following categories of sensitive information:

• Financial data

All personal information you provide must be accurate, complete, and up to date. You must notify us of any changes.

Information Automatically Collected

In Short: Certain information — such as your IP address and browser or device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate our Services. This information does not reveal your specific identity but may include device and usage data, such as your IP address, browser type, operating system, language preferences, referring URLs, device name, country, and information about how and when you use our Services. This information is used to maintain the security and operation of our Services and for internal analytics purposes.

Location Data. We may collect location information based on your device's IP address. You can opt out by disabling location settings on your device, though this may limit certain features of our Services.

Information Collected From Other Sources

In Short: We may collect limited data from public databases, marketing partners, and other external sources.

To enhance our ability to provide relevant services and marketing, we may obtain information about you from public databases, joint marketing partners, affiliate programmes, data providers, and other third parties. This may include mailing addresses, job titles, email addresses, phone numbers, intent data, IP addresses, and social media profiles.

In Short: We process your information to provide, improve, and administer our Services, communicate with you, prevent fraud, and comply with law.

We process your personal information for the following reasons:

• To facilitate account creation and authentication. We may process your information so you can create and log in to your account.
• To deliver our services. We process your information to provide the financial advisory and FX, banking, and payment services you have requested.
• To send you communications. We may process your information to send service-related updates, marketing materials (where you have opted in), and other relevant communications.
• To prevent fraud and ensure security. We process your information to detect, investigate, and prevent fraudulent transactions and other illegal activities.
• To comply with legal obligations. We may process your information where required by applicable law or regulation.
• To protect vital interests. We may process your information where necessary to prevent harm to you or others.

In Short: We only process your personal information where we have a valid legal basis to do so under applicable law.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the legal bases we rely on when processing your personal information:

• Consent. We may process your information where you have given us clear permission to do so for a specific purpose. You may withdraw your consent at any time by contacting us.
• Performance of a Contract. We may process your information where necessary to fulfil our contractual obligations to you, including providing our advisory services.
• Legal Obligations. We may process your information to comply with applicable laws, cooperate with regulatory bodies, or exercise our legal rights.
• Legitimate Interests. We may process your information where it is in our legitimate business interests to do so, provided those interests are not overridden by your rights and interests.
• Vital Interests. We may process your information where necessary to protect your vital interests or those of a third party.

If you are located in Canada, this section applies to you.

We may process your information where you have given express or implied consent, or where permitted by applicable Canadian law without consent — for example, for fraud prevention, business transactions, legal proceedings, or where collection is clearly in the interests of the individual.

In Short: We may share information in specific situations and with specific categories of third parties.

Service Providers and Partners. We may share your data with third-party vendors, service providers, contractors, or agents who perform services on our behalf. We have appropriate data processing agreements in place with such parties to safeguard your information. Categories of third parties include:

• Technology and IT service providers
• Marketing and analytics tools
• Banking and financial institution partners
• Compliance and regulatory service providers

We may also share your information in the following circumstances:

• Business Transfers. We may share or transfer your information in connection with a merger, acquisition, sale of company assets, or financing.
• Affiliates. We may share information with our affiliates, who are required to honour this Privacy Notice.
• Business Partners. We may share your information with trusted business partners to offer you relevant products, services, or promotions.
• Legal Requirements. We may disclose your information where required by law, court order, or regulatory authority.

In Short: We retain your information for as long as necessary to fulfil the purposes described in this Notice, unless otherwise required by law.

We retain personal information only for as long as necessary for the purposes set out in this Notice, unless a longer retention period is required or permitted by law (for example, for tax, accounting, or regulatory compliance purposes). In general, we will not retain your personal information for longer than twelve (12) months after the termination of your engagement with us, unless legally required to do so.

When we no longer have a legitimate need to process your information, we will either delete or anonymise it. Where this is not immediately possible (for example, where data is held in backup archives), we will securely isolate it from further processing until deletion is possible.

In Short: We protect your personal information through appropriate organisational and technical security measures.

Alto Global Partners Limited has implemented reasonable and appropriate technical and organisational measures to protect the security of your personal information. However, no electronic transmission over the internet or information storage system can be guaranteed to be entirely secure. While we do our best to protect your data, transmission of personal information to and from our Services is at your own risk. We recommend accessing our Services only within a secure environment.

In Short: We do not knowingly collect data from or market to individuals under 18 years of age.

Our Services are intended for business professionals and are not directed at children under the age of 18. We do not knowingly solicit or collect data from minors. By using our Services, you represent that you are at least 18 years of age. If we become aware that personal information has been collected from anyone under 18, we will promptly deactivate their account and delete the relevant data. If you believe we may have collected information from a minor, please contact us at info@alto-global.com.

In Short: Depending on your location, you may have specific rights regarding access to and control over your personal information.

If you are located in the European Economic Area (EEA), United Kingdom (UK), or Canada, you have rights under applicable data protection laws, which may include:

• The right to access and obtain a copy of your personal information
• The right to request rectification or erasure of your personal information
• The right to restrict or object to the processing of your personal information
• The right to data portability (where applicable)
• The right to withdraw your consent at any time (where processing is based on consent)

To exercise any of these rights, please contact us using the details provided in Section 11 below. We will respond in accordance with applicable data protection laws.

If you are located in the EEA or UK and believe we are unlawfully processing your personal information, you have the right to lodge a complaint with your local data protection supervisory authority.

Opting out of marketing communications. You may unsubscribe from our marketing communications at any time by clicking the unsubscribe link in any email we send, or by contacting us directly. You will be removed from our marketing lists, though we may still send you essential service-related communications.

Most web browsers and some mobile operating systems include a Do-Not-Track ('DNT') feature that you can activate to signal your preference not to have your browsing activities tracked. At this time, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT signals. If a standard is adopted that we are required to follow, we will update this Privacy Notice accordingly.

In Short: Yes, we will update this Notice as necessary to remain compliant with applicable laws and to reflect changes in our practices.

We may update this Privacy Notice from time to time. Any changes will be indicated by an updated date at the top of this Notice and will take effect as soon as they are published. Where we make material changes, we may notify you by posting a prominent notice on our website or by sending you a direct communication. We encourage you to review this Notice periodically to stay informed about how we protect your information.

If you have any questions or comments about this Privacy Notice, you may contact us by email or post:

Based on applicable laws, you may have the right to request access to, correction of, or deletion of the personal information we hold about you. To submit a request, please contact us using the details provided in Section 11 above. We will respond to your request in accordance with applicable data protection legislation.