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Privacy Policy

Effective Date: January 12, 2026 · Last Updated: February 21, 2026

PRIVACY POLICY

WOUFX LLC

This Privacy Policy (the "Policy") describes how WOUFX LLC (the "Company", "WOUFX", "we", "us", or "our") collects, uses, stores, discloses, and protects personal data of users of the website woufx.com, clients of the WOUFX TRADE platform (the "Platform"), and individuals interacting with the Company (the "User" or "Client").

This Policy forms an integral part of the Client Agreement, Legal Information and Full Disclosure, AML/KYC Policy, Order Execution Policy, and other corporate documents adopted under the WOUFX LLC Operating Agreement.

The Company operates strictly under the 100% A-Book ECN DMB execution model. B-Book and Hybrid execution models are strictly prohibited and are not used under any circumstances. Services are not provided to U.S. Persons or to individuals from sanctioned jurisdictions.

1. DATA CONTROLLER

The Data Controller is:

WOUFX LLC

  • 1209 North Orange Street, Suite 100, Wilmington, Delaware 19801, USA
  • File No.: 10372381
  • Business License No.: 2025715007
  • FinCEN MSB Registration: 31000315645596
  • LEI: 984500386C3CN4BF4710
  • UK ICO Registration: ZC023067

Data Protection Officer (DPO): Mr Shoxjahon Eshniyozov

Email: privacy@woufx.com

WOUFX LLC determines the purposes and means of processing personal data.

2. CORPORATE STRUCTURE AND DATA PROCESSING

Certain technical, infrastructure, liquidity administration, clearing and settlement support functions may be performed by:

WOUFX Technologies Ltd. (Saint Lucia, Registration No. 2026-00018)

Registered Office: Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, Saint Lucia

Operational Administrative Office: Pindou 10, Thalia Block 2, Office 102, 8220 Chloraka, Paphos, Republic of Cyprus

Where applicable, WOUFX Technologies Ltd. acts strictly as a data processor under a written intercompany data processing agreement and processes personal data solely on documented instructions of WOUFX LLC. It does not act as an independent controller and does not establish direct client relationships.

All contractual and regulatory obligations toward Clients remain exclusively with WOUFX LLC.

3. DATA WE COLLECT

The Company collects only data necessary for provision of margin trading services under the 100% A-Book ECN DMB model and to comply with AML/KYC/BSA obligations.

3.1 Identity and Contact Data

Full name, date and place of birth, citizenship, residential address, email, telephone number, identity documents.

3.2 AML/KYC and Compliance Data

Passport/ID, proof of address, tax residency (CRS/FATCA), Source of Funds / Source of Wealth documentation, sanctions and PEP screening results, adverse media checks.

3.3 Financial and Payment Data

Trading account ID, transaction history, bank account or wallet identifiers (full card numbers are not stored; processing performed by PCI DSS-certified providers).

3.4 Trading Data

Order history, execution reports, open positions, commissions, swaps, platform logs, margin and Stop Out calculations.

3.5 Technical Data

IP address, geolocation (approximate), device/browser information, operating system, login timestamps, 2FA logs, cookies.

3.6 Communication Data

Support correspondence, uploaded documents, recorded communications where permitted by law.

4. SOURCES OF DATA

Data is obtained:

  • • Directly from the Client
  • • Automatically via Platform technologies
  • • From third-party compliance vendors and payment providers
  • • From public sanctions/PEP registries
  • • From liquidity providers (anonymised execution data only)

5. PURPOSES OF PROCESSING

5.1 Service Provision

Account management, ECN order routing, execution, margin calculation.

5.2 Regulatory Compliance

AML/KYC verification, sanctions screening, reporting under BSA and FinCEN.

5.3 Security

Fraud prevention, cybersecurity, internal audit.

5.4 System Improvement

Performance analytics and technical optimization.

Processing is based on:

  • • Contractual necessity
  • • Legal obligation (AML/BSA/FinCEN)
  • • Legitimate interest (security, fraud prevention, system integrity)
  • • Consent (for marketing or optional cookies)

7. DATA DISCLOSURE AND RECIPIENTS

Personal data may be disclosed only to:

  • • Compliance vendors
  • • Banks and payment providers
  • • IT, hosting and security providers
  • • Professional advisers
  • • Competent authorities where legally required

Where technical infrastructure or operational support is performed by WOUFX Technologies Ltd., such processing occurs strictly under intercompany data processing arrangements and under the sole authority of WOUFX LLC as Data Controller.

Liquidity Providers receive anonymised execution data only and do not receive Client-identifying information.

Sale of personal data is strictly prohibited.

8. CROSS-BORDER DATA TRANSFERS

Data may be processed in jurisdictions where the Company or its authorized processors operate, including Saint Lucia and the Republic of Cyprus. Transfers are conducted subject to contractual safeguards consistent with applicable data protection laws and AML/BSA obligations.

9. DATA RETENTION

Data is retained only as long as necessary for the stated purposes.

Mandatory retention under BSA/FinCEN: minimum five (5) years from last transaction or account closure.

10. SECURITY MEASURES

The Company implements commercially reasonable technical and organizational safeguards, including:

  • • Encryption in transit and at rest
  • • Multi-level access control
  • • Continuous monitoring
  • • Incident response procedures
  • • Alignment with ISO/IEC 27001 principles (without certification claim)

11. CLIENT RIGHTS

Subject to applicable law, Clients may:

  • • Access their data
  • • Request correction
  • • Request deletion (subject to AML retention rules)
  • • Restrict or object to processing
  • • Request portability
  • • Lodge complaint with relevant supervisory authority (including UK ICO where applicable)

Requests require identity verification and should be sent to privacy@woufx.com.

12. MARKETING

Marketing communications are sent only where consent is provided or permitted by law. Clients may opt out at any time.

13. MINORS

Services are intended exclusively for persons over 18 years of age.

The Company is not responsible for privacy practices of external websites.

15. POLICY UPDATES

The Company may amend this Policy at any time. Continued use of services after publication constitutes acceptance.

CONTACT INFORMATION

  • Privacy: privacy@woufx.com
  • Legal: legal@woufx.com
  • Support: support@woufx.com

Questions about this document: legal@woufx.com