Table of Contents
Introduction
Information We Collect or Receive
Sources of Personal Information
How The Information Is Used
How We Protect Your Information
Retention of Your Information
Communication Preferences
Changes To This Privacy Policy
Contact Us

1.  Introduction

We thank you for joining Ferretti Capital Ltd. Your trust is important to us, and we are committed to protecting the privacy and security of your personal information. The personal information you share with us helps us provide you a great experience with Ferretti. That is why we want to keep you informed of the personal information we collect, how it is used, and when it is shared. We are dedicated to protecting the personal information we collect from you and ensuring that it is handled with care and attention.

1.1 Scope

This Privacy Policy applies to Ferretti Capital Ltd.

This Privacy Policy describes how we collect, use process, and disclose your personal information, in conjunction with your access to and use of the Ferretti Services (the “Services”). Our Services are available to you through a variety of platforms, including, but not limited to, www.ferretticapital.com (the “Site”).

In addition to the information provided in this Privacy Policy, Ferretti is required by certain laws to provide consumers with information regarding our collection and sharing of nonpublic personal information. Please see our Privacy Notice for more information.

1.2 Description of Users and Acceptance of Terms

This Privacy Policy applies to visitors to Ferretti who view publicly accessible content (“Visitors”) and clients who have signed up to access and use the Services offered by Ferretti.

By visiting or browsing the publicly accessible areas of the Site, Visitors are acknowledging that they have read, understood, and agree to be legally bound by this Privacy Policy and our Terms of Use. If you do not agree to any of the terms in this Privacy Policy or the Terms of Use, you may not access or use the Site.

By signing up, accessing, or using our Services, each Client is agreeing to the terms of this Privacy Policy, the Terms of Use, and any applicable client agreements.

1.3 Exclusions

The following exclusions apply to this Privacy Policy:

This Privacy Policy does not apply to third-party products, websites, links, services, or the practices of companies that we do not own or control, including other companies you might interact with on or through the Services.

2.  Information We Collect or Receive

In the course of operating the Site and providing the Services, we collect or receive the following categories of information, which collectively comprise “Personal Information”.

2.1 Categories of Personal Information

When you register to become a Ferretti Client, you will be asked to provide us with certain information about you, such as:

• Your name, alias, date of birth, citizenship and passport number, home address, telephone number, email address, bank account number, bank routing number, bank account login credentials, bank name, employer name, employment status, and job
• We may collect information derived or resulting from voluntary surveys. We may also collect Personal Information when you voluntarily provide us with Personal Information as a Visitor, such as when you use our “Contact Us” form.
• You may make changes to your Personal Information by contacting us at ….

2.2 Nonpublic Personal Information

When you become a Client, and at certain times following initial registration during the provision of our Services to you, we will also collect your nonpublic personal information, which means (i) any information you provide to us to obtain a service from us, (ii) any information about you resulting from any transaction involving a service between you and us, (iii) any information about a transaction, purchase, or sale you are seeking to execute through the Services, or (iv) any information we otherwise obtain about you in connection with providing a service to you (collectively, the “Nonpublic Personal Information”). We may also collect Nonpublic Personal Information from Visitors to our Site.

2.3 Information We Collect from You Automatically

We may automatically collect or receive information about you, your use of the Site, your interactions with us, as well as information regarding your computer or other devices used to access your Account, such as:

• Online Identifiers: operating system, browser name and version, and/or personal IP
• Biometric information: distinguishing physical or behavioral biological human characteristics used to identify a person, including, but not limited to, fingerprints, hand or facial geometry or patterns, voice characteristics, typing cadence, and signatures, and screen behavior, either singly or in combination with other identifying
• Device Information: type of device, device ID, Universally Unique Identifier, advertising identifiers (“IDFA” or “AdID”), operating system and version, wireless carrier, and network
• Usage Data: authentication data, security questions, click-stream data, public social networking posts, login data, transaction data, and use of the Site (including, but not limited to, linking your external bank account to your Client Account, depositing funds into your Client Account), and other data collected via web beacons, pixel tags, embedded links, cookies, and other similar tracking techniques.
• Cookies: A cookie is a piece of information that the computer that hosts the Site gives to your browser when you access the Site or Client Account. Our cookies help provide additional functionality to the Site and help us analyze the Site usage more accurately. For example, the Site may set a cookie on your browser that allows you to access the Site without needing to reenter your password each time. In all cases in which we use cookies, we will not collect Personal Information unless we obtain your permission. Please refer to the “help” section on your browser’s toolbar for information on how to receive notifications when you are receiving a new cookie and how to turn cookies off. If you do not want Ferretti to place cookies in your browser, you can opt-out by setting your browser to reject cookies or to notify you when a website tries to put a cookie in your browser software. If you choose to disable cookies in your browser, you can still use the Site, although your ability to use some of the features may be affected.

2.4 Children’s Data

Ferretti does not knowingly collect or receive Personal Information from children under the age of 18, except as described in this Privacy Policy. Generally, if a user submitting personal information is suspected of being younger than 18 years of age, Ferretti will require the user to close their account and will not allow the user to continue accessing the Site. We will also take steps, as appropriate, to delete the information. Please notify us if you know of any individuals under the age of 18 accessing our Site, so we can determine what actions should be taken to protect these children.

3.  Sources of Personal Information

• Information Collected by or Received from Third-Party Sources

We may also collect Personal Information about you from third-party sources, such as banking verification services, consumer reporting agencies, unaffiliated third-party service providers, brokers, banks, or government databases. We may combine data we collect about you from third-party data sources with data we collect from you and may use and share such data as

described in this Privacy Policy. All information we collect or receive from such third-party sources is referred to as “Third-Party Information.”

We use world check for our client due diligence. By using our Services, you grant us the right, power, and authority to act on your behalf to access and transmit your personal and financial information. You agree to your personal and financial information being
transferred, stored, and processed by our staff.

We also use certain third-party service providers to assist with operating the Site, including, but not limited to, detecting or preventing fraud, spam, abuse, security incidents, and other harmful or illegal activity, conducting security investigations or risk assessments, or verifying or authenticating certain information or identifications provided by you. You agree to Ferretti sharing your information with such third-party service providers.

4.  How the Information Is Used

Our primary purpose in collecting information about you is to provide you with a secure, smooth, efficient, and customized experience. We may use information about you to (1) provide, understand, improve, and develop the Site and Services, (2) create and maintain a trusted and safe environment (such as to comply with our legal obligations) and (3) provide, personalize, measure, and improve our Services.

4.1 Provide, Improve, and Develop the Site and Services

We may use Personal Information to provide, improve, and develop the Site and Services, including, for example:

• To enable you to access and use the Site and Services.
• To fulfill our contractual obligations to you or any requests by you for support.
• To maintain or service Client Accounts, process or fulfill orders and transactions, or verify Client information.
• To engage third-party service providers to perform certain functions on our behalf, including, for example, website hosting, mailing information, maintaining databases, ID verification, processing applications, processing and completing transactions.
• We process your Personal Information for these purposes given our legitimate interest in improving the Site and Services and our Clients’ experience with it, and where it is necessary for the adequate performance of our contractual obligations with

4.2 Create and Maintain a Trusted and Safe Environment

We may use Personal Information to create and maintain a trusted and safe environment, including, for example:

• To comply with our legal obligations, including detecting and preventing fraud, spam, abuse, security incidents, and other harmful or illegal activity, or to conduct security investigations and risk assessments.
• To verify or authenticate information or identifications provided by you, or to conduct checks against databases and other information sources, including background checks, to the extent permitted by applicable laws and with your consent where
• To ensure compliance with and enforce our Terms of Use, Privacy Policy, other policies, Disclosures, Notices, Agreements, or Terms and Conditions.
• To resolve any disputes with any of our Clients and enforce our agreements with third
• To conduct debugging to identify and repair errors.
• To share your Personal Information with any of our
• To share your Personal Information with any of our third-party service providers who perform services for us and help us operate our business.
• To comply with a court order or other lawful request or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Ferretti, (iii) act in urgent circumstances to protect the financial security of users of the Site or the public against fraud or other harm, or (iv) protect against legal
• We process your Personal Information for these purposes given our legitimate interest in protecting the Site and Services, to measure the adequate performance of our contractual obligations with you, and to comply with applicable

5.  How We Protect Your Information 

The security of your Personal Information is of utmost importance to us. Ferretti handles sensitive financial client data, so we have taken steps to secure critical systems and information. For example, we use encryption to protect and secure all of your information, from personal data to your transaction history. We take commercially reasonable technical, administrative, and physical safeguards to protect information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.

If you know or have reason to believe that your Personal Information or Client Account has been stolen, misappropriated, or otherwise compromised, or if you receive an unsolicited email or other electronic communication that appears to be from Ferretti, but you suspect it may be from some other source or fraudulent, please contact us immediately.

6.  Retention of Your Information

We will retain your Personal Information for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy or subsequently authorized. We will also retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If your relationship with Ferretti ends, we will not

destroy your Information unless required or permitted by law. We will continue to treat your Personal Information in accordance with this Privacy Policy and applicable laws.

7.  Communication Preferences

You have choices on the messages you choose to receive.

As a user of the Services, we will send you administrative and transactional communications that are necessary to provide the Services, such as billing, brokerage, fraud, or service notifications.

When you sign up for our Services, we will send periodic emails to you regarding the Services. You may not opt out of these emails pursuant to our Client Services Agreement, which you signed.

By providing your phone number, you expressly consent to Ferretti and/or its agents calling or texting you using an automated telephone dialing system and/or prerecorded messages, even if you incur charges for receiving such communications. For example, we may send you informational text messages to your mobile device in order to better service your account. You can revoke your consent to receiving informational text messages at any time by replying “STOP” or following any other instructions included in these text messages. For more information about receiving marketing communications through calling or texting, please see our Ferretti Terms and Conditions.

8.  Changes to This Privacy Policy

We may modify this Privacy Policy from time to time which will be indicated by changing the date at the top of this page. If we make any material changes, we will notify you by email (sent to the email address specified in your account), by means of a notice on the Site prior to the change becoming effective, or as otherwise required by law. Your continued access to or use of the Site after we make any changes to this Privacy Policy, will be subject to the revised Privacy Policy.

9. Contact Us 

If you have questions or concerns regarding this Privacy Policy, about Ferretti’s information handling practices, or if you have a complaint, please contact us by emailing us at info@ferretticapital.com.

FACTS	WHAT DOES FERRETTI DO WITH YOUR PERSONAL INFORMATION?
Why?	Financial companies choose how they share your personal information. Laws give consumers the right to limit some but not all sharing. Laws also require us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?	The types of personal information we collect, and share depend on the product or service you have with us. This information can include: ·      Personal identifying information ·      Account balances and transaction information
How?	All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Ferretti chooses to share; and whether you can limit this sharing.

Reasons Ferretti can share your personal information	Does Ferretti Share?	Can you limit this sharing?
For our everyday business purposes— such as to conduct our Know Your Client due diligence, process your transactions, maintain your account(s), respond to court orders and legal investigations	Yes	No
For our marketing purposes—to offer our products and services to you	Yes	No
For our affiliates’ everyday business purposes—information about your transactions and experiences	Yes	No

Questions: Email us at info@ferreticapital.com