ECM Terminal

1. Introduction

1.1

This Privacy Policy describes how Erguvan Decarbonization Technologies Ltd., operating the ECM Platform, collects, uses, stores, and discloses personal data in connection with access to and use of the ECM website and platform (together, the "Platform"). This Policy applies to website visitors, prospective users, and platform users. Certain processing activities described in this Policy apply only to individuals who have completed onboarding and entered into contractual arrangements with ECM.

2. Data Controller

2.1

Erguvan is the data controller for the purposes of applicable data protection laws.

2.2

Erguvan Decarbonization Technologies Ltd. 59 Terrington Hill, Marlow, SL7 2RE United Kingdom

3. Categories of Personal Data

3.1

Depending on the nature of the interaction, ECM may process the following categories of personal data:

(a)identification and contact information (such as name, business email address, employer, role);
(b)account and access information (such as user identifiers, authentication data, access logs);
(c)communications and correspondence;
(d)technical and usage data (such as IP address, device information, browser type, timestamps);
(e)compliance and due diligence information (including KYC, AML, sanctions screening data), where applicable;
(f)transaction-related or registry-related information, where applicable to onboarded Participants.

3.2

ECM does not intentionally collect sensitive personal data unless required to comply with legal or regulatory obligations.

4. Purposes of Processing

4.1

Personal data is processed, as applicable, for the following purposes:

(a)operating, maintaining, and securing the website and platform;
(b)responding to enquiries and communications;
(c)onboarding, identity verification, and eligibility assessment;
(d)compliance with legal, regulatory, and contractual obligations;
(e)prevention of fraud, misuse, or unauthorised access;
(f)operation of trading, clearing, settlement, custody, or registry-related processes, where contractually applicable;
(g)record-keeping, audit, and internal governance.

5. Legal Bases for Processing

5.1

Personal data is processed on one or more of the following legal bases, as applicable:

(a)performance of a contract or steps taken prior to entering into a contract;
(b)compliance with legal or regulatory obligations;
(c)legitimate interests pursued by ECM, including platform security, risk management, and operational integrity;
(d)consent, where required by applicable law.

6. Data Sharing and Disclosure

6.1

Personal data may be disclosed to:

(a)service providers and vendors supporting ECM's operations, systems, and infrastructure;
(b)financial institutions, registries, clearing or settlement service providers, where applicable;
(c)professional advisers, auditors, and insurers;

6.2

regulators, authorities, or law enforcement bodies, where required by law or regulation.

6.3

ECM does not sell personal data.

7. International Transfers

7.1

Personal data may be transferred to and processed in jurisdictions outside the United Kingdom or European Economic Area. Where such transfers occur, ECM implements appropriate safeguards in accordance with applicable data protection laws.

8. Data Retention

8.1

Personal data is retained only for as long as necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, and contractual requirements. Retention periods may vary depending on the nature of the data and the relationship with ECM.

9. Data Security

9.1

ECM implements technical and organisational measures designed to protect personal data against unauthorised access, disclosure, alteration, or destruction, consistent with its operational and regulatory obligations.

10. Individual Rights

10.1

Subject to applicable law, individuals may have the right to:

(a)request access to their personal data;
(b)request rectification or erasure;
(c)restrict or object to processing;
(d)request data portability;
(e)withdraw consent, where processing is based on consent.

10.2

Requests may be submitted using the contact details below.

11. Cookies and Similar Technologies

11.1

Information regarding the use of cookies and similar technologies is set out in ECM's Cookie Policy, as published on the website.

12. Updates to This Policy

12.1

ECM may update this Policy from time to time. The current version will be made available on the website, with the effective date indicated above.

13. Contact

13.1

Questions or requests relating to this Policy or the processing of personal data may be directed to ecm@erguvan.co, or such other address as notified by ECM.