Privacy Policy

This privacy policy (the “Policy”) explains how the eToro group (collectively eToro, “we” or “us” and each member of the eToro group for whose services you registered, the “eToro Entity”) collects, uses and discloses personal information through its websites, mobile applications, and other online products and 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.

The Services include providing: (i) the eToro social trading platform for investing in stocks & EFTs, cryptocurrencies and for CFDs trading which users can sign up for an account with ; (ii) the eToro Money App which facilitates the eToro Money services (e-money account servicing payments and debit card) and eToro Money Crypto Wallet services; (iii) eToroX Digital Assets Exchange Services; (iv) any other site, web platform, mobile application or other service facilitated by any eToro Entity (any account described in (i)-(iv) being an “eToro Account” for the purpose of this Policy).

We encourage you to read the Policy carefully as it forms part of the relevant eToro Entity’s terms and conditions, terms of business, agreement with you and/or terms of use, as the case may be.

If you accept or agree to this Policy on behalf of a company or other legal entity, you represent and warrant that you have the authority to bind that company or other legal entity to the Privacy Policy and, in such event, “you” and “your” will refer and apply to that company or other legal entity.

Application of this Policy

For the purposes of applicable state and/or international data protection laws, the respective eToro Entity with whom you have registered is the “controller” of personal information collected through www.etoro.com (http://www.etoro.com), other eToro group entities’ websites, widgets, mobile applications (including the eToro Money App) and other platforms (together the “Site”), and is the company to contact if you have questions about the use of your personal information (see the “Contact Us” section below). The Policy also applies to personal data about each authorized representative of a client and about other persons or entities where this personal data is collected in the course of providing the Services (such as directors of corporate clients).

Collection of Information

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information when you create an eToro Account, participate in any interactive features of the Services, fill out a form, participate in a contest or promotion, make a purchase, communicate with us via third party social media sites, request customer support, or otherwise communicate with us

When You Sign Up or Register for an eToro Account or Services

If you sign up for an eToro Account or other Services, we will collect basic information about you including your name, email address and telephone number. You may provide this information to us directly, or by signing in to your account/service with a third party, including without limitation, Facebook or Google (see “Information We Collect from Other Sources” below). We will use the information that we collect about you to:

• Create and maintain your eToro Account;
• Allow you to log in to eToro;
• Contact you about your eToro Account and/or our Services (this may include marketing emails).

When You Provide Information to Build Your Profile

Once you have created an eToro Account, we will ask you to provide additional information to allow you to make use of certain functions. We will ask you to provide a copy of an identification document, such as a passport, residency permit, visa or national identity card, a utility bill and such other documents as may be required by us in order to comply with our regulatory obligations and to verify your identity. Further details about the identification process can be found in the relevant eToro Entity’s terms and conditions, terms of business and/or terms of use or client/customer agreement, as the case may.

Please note that if you choose to provide additional information about yourself to complete your “Profile”, then the information we ask for may include your gender, date of birth, place of birth, addresses, nationality, national insurance number, social security number (or other governmentissued identification number), citizenship and residency status, Tax ID, and information about your experience trading, education, source of income, investment aims and appetite, occupation, employer and employment position, annual income, investment portfolio, total cash and liquid assets and other details or questions as may be required in the Profile creation and the process may be amended by us from time to time.

It is optional for you to do so but for legal and regulatory reasons you will be unable to proceed to use certain features unless you provide further information.

We will use the information you provide in your Profile to:

• verify your identity and carry out checks that we are required to conduct by applicable laws and regulations, including without limitation, “know your customer” (KYC), antimoney laundering, fraud, sanctions and politically exposed person (PEP) checks;
• contact you on matters related to your eToro Account, including to request any additional information or documentation;
• provide you with notices related to your eToro Account, general updates, market updates and other marketing materials, including about the Services offered by members of the eToro Group;
• tailor the products and services offered through the Site to you, including without limitation, to perform any suitability or appropriateness assessments for using our services and/or products, such as our high-leveraged trading services and Social Trading Features;
• assess your credit risk;
• assess your risk score according to parameters determined by eToro;
• assess whether you qualify as a professional client, wholesale client or other specific category of client;
• maintain administrative records relating to our business;
• set up security measures to secure your account, including without limitation, to carry out two-factor authentication (“2FA”); and
• provide the Services.

You can update your Profile at any time by visiting the “Account” page in the Settings menu when logged into your eToro Account. We recommend that you update your Profile regularly, to ensure that the eToro functions offered to you are appropriate for your current circumstances. You further agree to update such information upon eToro’s request, if eToro considers the information -4- provided as untrue, incorrect, incomplete and/or inconsistent with other information provided by you at any time. You acknowledge that we may rely upon such information and that you are responsible for any damages or losses which may result from any inaccuracies, including without limitation, the inappropriateness of our Services to your Profile. You do not have to complete your Profile and therefore do not have to provide the information; however, if you choose not to, we will be unable to offer eToro’s full functionality to you.

When You Contact Us

If you contact us by telephone, email, post or use another function offered by eToro, such as the chat feature, we will collect any information about the communication and any additional information that you choose to give us. We will use this information to review, investigate and respond to any comment or question that you may raise. Please note that we record and retain all telephone calls and other communication with us and may use it in our dealings with you, including any dispute resolution or legal proceedings.

When an eToro User Invites You to Use eToro

Users of eToro can invite their contacts to sign up for an account with us. We only collect the email addresses of individuals that users choose to invite to join eToro and eToro only uses the email addresses for sending an invitation to the individual at the request of the existing eToro user.

Information About Your Use of the eToro Services

Usage and Automatically Collected Information

When you access or use our Services, we automatically collect information about you (the type of information depends on the Site you are using), including:

• Financial Information: We collect financial information related to your use of the Services, including information you provide to us or that we collect from public sources.
• Log Information: We collect log information about your use of the Services, including the type of browser you use, app version, access times, pages viewed, your IP address, any other network identifiers, and the page you visited before navigating to our Services.
• Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
• Activities on the Site: We collect records of activities on the Site, including, any content you post, your eToro Account details, the time, value and currency of any deposit, withdrawal, or transaction made and the payment method.
• Location Information: In accordance with your device permissions, we may collect information about the geo-location of your device.
• Information Collected by Cookies and Other Tracking Technologies:We use different technologies to collect information, including cookies and web beacons. You can find out more about eToro’s use of cookies and similar technologies in our Cookie Policy.

If you are an eToro Money customer, please also see the section “eToro Money” below.

Information We Collect from Other Sources

We may collect personal information about you from third party entities when we seek to verify your identity as part of our regulatory requirements. This may include, for example, identity verification agencies, credit referencing agencies and similar bodies. We may also collect information about you from third parties, when you use or connect to eToro by or through a third- party platform, such as Facebook or another site, you allow us to access and/or collect certain information from your third party platform profile/account as permitted by the terms of the agreement and your privacy settings with the third party platform. We will share such information with the third party platform for their use.

Some of the information we collect from you on installation of the mobile app will be shared by us with vendors and other service providers who are engaged by, or working with, us in connection with operating and analysing the Services we provide to you.

If you are an eToro Money customer, please also see the section “eToro Money” below.

Unsolicited Information

If you provide us with personal information that we have not requested then we will endeavour to only retain the information that we are entitled or required to hold because of the products and services we provide. However, if this additional information is surplus to our requirements but is provided to us in a manner where it is combined with information that we are either required or entitled to retain then you acknowledge that this unsolicited information may be held by us in the same manner as the balance of your personal information.

Use of Information

We use the information we collect to provide, maintain, and improve the Services, such as to administer, verify and maintain your account, to provide the Services you request and customize your experience with us. We also use the information we collect to:

• carry out our obligations owed to you;
• comply with our regulatory and other legal obligations;
• monitor/access any content you post;
• administer transactions including deposits, chargebacks and payments;
• monitor trading activity on eToro, including by detecting inconsistencies in payments and trades and looking out for potentially illegal activities;
• determine whether a payment method is being abused;
• compile statistical analysis of the pages of our platform and websites;
• monitor and analyse our business;
• investigate and to manage enquiries, disputes and legal proceedings and to comply with court orders, mandatory dispute resolution determinations and mandatory government authority or law enforcement orders or directions;
• provide information about you and your trading with us to credit reference/reporting agencies;
• participate in crime prevention, legal and regulatory compliance and to assist regulatory, cybercrime, data and information protection agencies and police with their enquiries and enforcement, even if not compelled to do so;
• develop and to market other products and services; and
• novate, transfer or assign any of the rights or liabilities of the eToro Entity.

Sharing of Information

We will not share the personal information we hold about you except in the following circumstances:

• between and among the eToro Entity, eToro and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership; and
• with professional advisors, vendors, consultants, and other service providers, such as payment service providers, IT hosting companies, banks, other financial institutions and credit reporting/reference agencies who need access to such information to carry out work on our behalf;
• in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of eToro by another company;
• disclosure in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
• if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property, and safety of eToro or others; or.
• where we have your consent. For example, if you use the “eToro Connect” feature, we will get your permission before sharing your personal information with a third party.

If you are an eToro Money customer, please also see the section “eToro Money” below.

Social Sharing Features

If you have elected to use one of our applications provided via social networks (such as Facebook, Twitter, etc.), our application will be granted access to your social network account general information which includes your name and username in the social network, profile picture, gender, networks, user ID, list of friends, and any other information you have permitted to be shared depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Advertising and Analytics Services Provided by Others

We may allow others to provide analytics services and serve advertisements about our products and services on our behalf across the web and in mobile applications. This may involve cookies and other technologies to collect information about your use of the Services. This information may be used by eToro to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services, and better -6- understand your online activity in connection with the Services. Please refer to our Cookie Policy for more information about the cookies involved and the process of consenting or refusing cookies. For more information about interest-based ads generally, please visit www.aboutads.info/choices if you are in the United States and if you are in the EU or the UK, please visit www.youronlinechoices.eu/.

Your Choices and Rights

You may have certain rights and protections under the law regarding the processing of your personal data. For example, you may also have the right to object to, or request that we restrict, certain processing and in some circumstances to obtain a copy of the personal information in machine readable format. There are limits to such rights where they apply and in certain circumstances we may not be required or able to meet your request, or we may only meet your request in part.Data Subject Requests

Legal Basis for Processing: For transparency purposes (where relevant under data protection legislation applicable to our processing of your personal information) we process your personal data on the following legal grounds:

• Entering into and Performing the Contract with You: If you have an eToro Account or have registered on the Site or for the Services, our legal basis for processing your personal information is that it is necessary for the performance of the relevant eToro Entity’s terms and conditions, terms of business and/or terms of use, and to provide the requested service to you. With respect to an eToro Account, this includes facilitating access to our platform, processing payments and executing trades.
• For other Justifiable Grounds, including Legal Obligation and Legitimate Interests: We process your personal information where necessary for eToro to comply with legal and regulatory obligations we are under, and also where it is necessary for legitimate interests we have in conducting our business (or the legitimate interests of our partners in complying with their legal obligations), balanced against the rights of our customers, like you. These include without limitation:
• Learning about your interests and preferences to contact you with information that is relevant to you and helping us target marketing communications and advertisements for our products and services so that they are more relevant to you.
• Using your pseudonymised details to show you advertising for our products and services on social media platforms, such as Facebook or via other third-party advertising that may appear on other websites you use. The information shared with these platforms is pseudonymised to protect your personal data.
• Analyzing and continually improving the Site and the Services and helping us pilot test versions of the Site internally to develop new features and ensure the efficient running of eToro’s services.
• Detecting and reducing fraud and credit risk.

If you are an eToro Money customer, please also see the section “eToro Money” below.

Data Subject Requests: You may have the right to access personal data we hold about you and to ask that your personal data be updated, corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you can log into your account or contact us via this Link. Alternatively, you may also reach us by email at privacy@etoro.com. If you wish to delete or deactivate your account, please note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

Questions or Complaints: If you are interested in exercising any of these rights (or confirming if they apply to our processing of your personal data), you can log into your account or contact us. Any such request should be submitted in writing to: www.etoro.com/customer-service/. If you have a concern about our processing of personal data that we are not able to resolve, you may have the right to lodge a complaint with the relevant data protection supervisory authority where you reside. As noted above, even where such rights apply, they are subject to limits. This means that, in certain circumstances, we may not be required or able to meet your request, or we may only meet your request in part.

Promotional Communications

You may opt out of receiving promotional emails or text messages from eToro by following the instructions in those emails or text messages or by visiting the “Notifications” tab in the “Settings” menu on our platform. If you opt out, we may still send you non-promotional emails, such as service messages about your eToro Account or our ongoing business relationship.

Mobile Push Notifications/Alerts

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Transfer of Information to Other Countries

When using the Services, your data is processed and stored in the EU and other countries, including the United Kingdom. We and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide levels of data protection equivalent to your home jurisdiction.

Where we transfer personal data from the EEA or from the UK to countries outside of the EEA or UK which are not recognized as providing adequate data protection, we provide appropriate safeguards in the form of intercompany agreements based on the Standard Contractual Clauses authorised under EU law or UK law (as applicable). For further information, please contact us at privacy@etoro.com.

eToro Social Trading Platform

eToro provides a real-time social trading platform which integrates rich community and social characteristics into the trading platform. As part of the eToro traders’ network, traders who choose to be part of the community share their strategies and performance with the community. The amount traded is never publicly disclosed and all these traders have expressly agreed to be part of the network and share their strategies and performance.

Downloading, installing and accessing the eToro Services in relation to the trading platform constitutes your agreement and acknowledgment that the following information and content shall be considered non-confidential and non-proprietary information (other than your personal data as described below), collectively, the “Content” and shall be publicly shown on the Site: your username and full name, your picture/avatar (if provided), your state of residency, gender, networks, list of users who follow you, users who copy you, stats related to your trades etc., list of users you follow or copy, and any network status/posts/blogs and any other content options that enable our users to interact amongst themselves, including without limitation content and information you post on the eToro community, comments, feedback, postings, “likes”, blogs and/or all information that you provide to us via the Site, and/or by email, chat, fax or telephone and/or any other means.

You can change your privacy settings at any time, and can make your trading activity private by clicking here: https://www.etoro.com/settings/privacy and https://www.etoro.com/settings/notifications.

eToro Money

If you are a customer of eToro Money, in addition to the uses of personal data explained in other parts of the Policy, the information in this section also applies.

eToro Money UK Ltd. and eToro Money Malta Ltd. are the regulated entities which provide the eToro Money products and services and are the relevant eToro Entities for this Service. eToro Ltd. provides and runs the relevant IT infrastructure (including the eToro Money App) on behalf of eToro Money.

Collection of Personal Data

When an eToro Money debit card is issued to a customer, eToro will receive the last 4 digits of the long card number (the PAN) from the third party issuer processor for the following purposes: (i) in order to be able to link information about transactions and related activities with the correct eToro Money Account/debit card instance; and (ii) allowing you to associate your debit card with related transactions made with such debit card. eToro does not receive the full card number, the card expiry date or CVV. eToro will never receive the security PIN used with your eToro Money debit card.

If you choose to set up payee information linked to your eToro Money Account (for example, the account number and sort code of a recipient you would like to send payments to from your eToro Money Account), then we will hold and use this information (as well as recipient account holder name) in order for you to do so.

As you use your eToro Money debit card, eToro will also receive a feed of transaction, balance and currency conversion information in order to update and service your eToro Money Account.

Your mobile phone number will be used to facilitate open banking and 3DS secure online transactions.

Sharing of Your Personal Data

To provide the eToro Money products and services, eToro will share your personal data with third parties including: agency banks which provide banking services, including issuing a sort code for UK clients, card networks, such as VISA, issuer processor, card processors and related service providers which support secure online payments and card manufacturers which produce and dispatch the physical card to you.

Retention of Personal Information

We store the information we collect on you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations. The period for which we will retain personal information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation. For example, if you are invited to use eToro by another user, we will store the personal information about you provided by such other user for a period of six months in order to send an invitation to you by email.

If you have an eToro Account, we will store your personal information for as long as you maintain that account, and after you cease holding an account, for as long as we are required to by laws and regulations that are applicable to us.

Security and Integrity of Information

We protect your personal information by using data security technology and using tools such as firewalls and data encryption. We also require that you use a personal username and password every time you access your account online. As set out in the relevant eToro Entity’s terms and conditions, terms of business and/or terms of use, you must not share your password with anyone else. We recommend that you do not re-use a password previously used by you for other platforms/services. We strongly encourage you to activate Two Factor Authentication (“2FA”) in your account. 2FA requires you to enter a verification code sent to you mobile phone via SMS in order to access your account.

We restrict access to personal information at our offices so that only officers and/or employees with a legitimate business purpose can access it.

Minors

eToro is not available for users under the age of 18 (or the age of legal consent for the jurisdiction the user is located in) (a “Minor”). We do not knowingly collect personal information from or about Minors. If you are a Minor, you should not download or use any of our services nor provide any personal information to us.

If we become aware that a Minor has shared any information with us, we will delete such information. If you have any reason to believe that a Minor has shared any information with us, please contact us at www.etoro.com/customer-service/.

Important Notice to Residents of the State of California

Natural persons who reside in the State of California should also review the Notice to California Residents. You may have additional rights under California law.

NEVADA PRIVACY RIGHTS

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us in accordance with the contact details set out below with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

Changes to this Privacy Policy

The Policy will be reviewed and updated from time to time to take account of changes to our operations or practices and, further, to make sure it remains appropriate in light of any changes in law, technology and the business environment. Any personal information held will be governed by our most current Policy. Please refer back to the Policy on a regular basis.

Links

The Site may include links to other websites on the internet. We are not responsible for the content of these sites or for any other privacy practices on these internet sites. You should read the terms of use and the privacy statements of any such websites. Our terms of use and our Privacy Policy apply only to information collected by us in accordance with this Policy.

Contact Us

Should you have any questions regarding the Policy, please contact our customer support and open a ticket via this Link. Alternatively, you may also reach us at: privacy@etoro.com and please include your full name, and email address so we are able to handle your query properly. We may require that you provide additional information to verify your identity before allowing you to exercise certain rights outlined above.