Privacy Policy

Effective as of: September 1, 2026

TICKWISE, a simplified joint-stock company (SAS) with share capital of 1000 €, registered with the Paris Trade and Companies Register under number 108 166 042, whose registered office is located at 173 rue de Courcelles 75017, Paris, France (hereinafter “TickWise”, “we”, “us” or “our”), undertakes to protect your personal data and respect your privacy.

This Privacy Policy informs you of how we collect, use, retain, disclose and protect your personal data when you access or use the website https://tickwisefunding.com (the “Site”), our proprietary technology platform (the “Platform”) and the associated services (collectively, the “Services”).

It has been prepared in accordance with the following instruments:

• Regulation (EU) 2016/679 of April 27, 2016, on the protection of personal data (GDPR);
• Law No. 78-17 of January 6, 1978, as amended, relating to information technology, files and civil liberties (the French Data Protection Act);
• The recommendations and deliberations of the Commission Nationale de l’Informatique et des Libertés (CNIL).

Article 0 - Data Controller and Contact Details

TickWise is the data controller responsible for the processing of personal data collected through the Site, the Platform and, more broadly, in connection with the provision of the Services. For any questions relating to this Privacy Policy or the protection of your data, you may contact us at the following address: TICKWISE, 173 rue de Courcelles 75017, Paris, France - email: compliance@tickwisefunding.com.

No Data Protection Officer (DPO) has been appointed at this stage. TickWise nevertheless remains fully responsible for ensuring that its processing of personal data complies with the GDPR and the French Data Protection Act.

Definitions

• “Personal Data”: any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more specific elements particular to that person’s identity.
• “Processing”: any operation or set of operations which is performed, whether or not by automated means, on Personal Data (such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction).
• “Website”: the website https://tickwisefunding.com.
• “Platform”: the proprietary technological platform operated by TickWise for the provision of the Services.
• “Services”: all services offered by TickWise via the Site and the Platform, including, in particular, the evaluation programs and the Funded Accounts and Broker Accounts.
• “User”: any individual who accesses the Site, creates an account or uses the Services offered by TickWise.
• “Client”: the User who actually subscribes to an evaluation program and, where applicable, benefits from a Funded Account or a Broker Account.

Article 1 - Personal Data That We Collect

We collect and process personal data relating to you in the following categories:

1.1 Data That You Provide Directly

When you register for or use our Services, or interact with us, you may provide us with personal data including, in particular:

• Identity and contact details: surname, first name, date of birth, residential address, postal code, email address, telephone numbers;
• Identity documents for KYC/AML checks: copy of an official identity document (national identity card, passport), proof of address, photograph. These checks are carried out when transitioning to a Broker Account, via the Docusign solution, which also provides for the electronic signing of contractual documents;
• Tax and financial information: tax identification number, banking details for payments. Payments of assessment fees are made exclusively by bank transfer via the Inflowpay open banking solution (account-to-account technology) - no bank card information is collected or stored by TickWise;
• Interactive content: responses to surveys, requests, opinions, comments, feedback, messages and any content submitted via the Platform;
• Marketing preferences: consent or refusal to receive promotional communications.

1.2 Automatically Collected Data

When you access or use the Website or the Platform, we automatically collect technical and usage information, including:

• Browsing Data: date and time of access, pages viewed, features used, session duration, and content submitted;
• Trading and Performance Data: order history, positions, and information relating to positions (timing (date and time, position duration), assets traded, quotations relating to your transactions), results, and your performance metrics on your evaluation accounts and your Funded Account;
• Technical Data: IP address, browser type and version, operating system, and device identifiers;
• Payment Data for Tickwise services: records of payments made via the Platform;
• Geolocation Data: when this feature is enabled on your device;
• Data derived from cookies and similar technologies: web beacons, pixels, and embedded scripts used to remember your preferences, track visits, collect analytics, optimise features, and personalise the experience. See our Cookie Policy for further details.

1.3 Data Received from Third Parties

We may receive personal data concerning you from third-party sources, including:

• Payment service providers: Inflowpay (processing of evaluation payments via open banking) and Rise Works (profit payouts from the Broker Account);
• Identity verification and electronic signature service providers: Docusign, used when transitioning to a Broker Account for identity verification (KYC) and the electronic signing of contractual documents;
• Social media platforms with which you interact through our official accounts;
• Analytics companies providing information on the use of our Services;
• Rithmic, provider of the technological infrastructure for the evaluation: Rithmic provides the systems and market data feeds enabling the operation of evaluation accounts (Challenge and Preparation Phase). Trading data generated by the User on the Platform is transmitted through Rithmic’s infrastructure in connection with the provision of the Services.

Article 2 - Legal Bases and Purposes of the Processing

TickWise processes your personal data only where a legal basis within the meaning of Article 6 of the GDPR applies. The table below sets out the purposes and legal bases of our processing activities:

Article 3 - Recipients and Sharing of Data

As a matter of principle, your personal data are not disclosed to third parties except in the cases described in this Policy. Any disclosure of data to third parties occurs exclusively (i) where necessary for the provision of the Services (in particular through our service providers and partners acting as processors), (ii) where required or authorised by law, or (iii) in connection with transactions involving TickWise’s share capital, as described below.

3.1 Internal sharing

Your personal data are accessible only to members of the TickWise team who require access to them in the course of their duties (support, compliance, technical and finance teams).

3.2 Third-party service providers

We share your data with third-party service providers acting in the capacity of processors within the meaning of the GDPR, in the strict context of the defined purposes and on the basis of data processing agreements compliant with Article 28 of the GDPR. These service providers include, in particular:

• Payment service providers: Inflowpay (payments for evaluations via open banking) and Rise Works (profit payouts);
• Hosting and cloud infrastructure provider: OVHcloud, a French company whose data centres used for the Services are located within the EEA;
• Identity verification and electronic signature provider: Docusign, for KYC verification and the signing of contractual documents when transitioning to a Broker Account;
• Sweet Futures (Introducing Broker - IB) and Dorman Trading (Futures Commission Merchant - FCM): Sweet Futures is the IB responsible for opening accounts and providing access to the Rithmic platform; Dorman Trading is the FCM regulated by the CFTC and responsible for the custody of funds and execution on futures markets;
• Audience analytics provider: Google Analytics (Google LLC), used to improve the performance of the Website and the quality of the user experience. This tool is only activated after obtaining your consent through our cookie management tool;
• Emailing and commercial communications provider: Brevo (formerly Sendinblue), used to send commercial and transactional communications only with your prior consent for marketing communications.

3.3 Authorities and legal obligations

We may be required to disclose your personal data to competent authorities (judicial authorities, TRACFIN, AMF, CNIL, tax authorities) where required to do so by law, in particular in connection with our AML/CFT obligations or judicial requisitions.

3.4 Transfers in connection with capital transactions

In the event of a merger, acquisition, disposal of assets or any other transaction affecting TickWise, your personal data may be transferred to the transferee, provided that the latter undertakes to comply with this Privacy Policy.

3.5 What we do not do

We never sell, lease or market your personal data to third parties for independent marketing purposes without your prior explicit consent. Your data may, however, be processed by certain of our technical and software service providers (in particular the Rithmic platform, used through our partners Sweet Futures and Dorman Trading), acting as sub-processors, exclusively on our behalf and in accordance with our instructions, under the conditions described in Article 3 above.

Article 4 - International Data Transfers

TickWise is established in France. Your personal data are primarily processed within the European Economic Area (EEA). Some of our service providers are located outside the EEA, notably Docusign (United States), Sweet Futures (IB - United States), Dorman Trading (FCM - United States), Rithmic (United States), Google LLC (Google Analytics - United States), and Inflowpay and Rise Works, depending on their respective infrastructures. OVHcloud, our hosting provider, and Brevo, our email service provider, are French companies whose data are processed within the EEA.

In such cases, we ensure that any transfer of data outside the EEA is governed by appropriate safeguards in accordance with Chapter V of the GDPR, in particular:

• An adequacy decision of the European Commission for the country of destination;
• Standard Contractual Clauses (SCCs) adopted by the European Commission;
• Binding Corporate Rules;
• Or any other lawful transfer mechanism recognised under the GDPR.

Upon a simple request sent to compliance@tickwisefunding.com, you may obtain a copy of the safeguards implemented for these transfers.

Article 5 - Retention Periods

We retain your personal data only for as long as necessary for the purposes for which it was collected, in compliance with the applicable legal obligations.

The general retention periods are as follows:

• Account and identification data: duration of the contractual relationship + 5 years (the ordinary limitation period);
• KYC/AML-CFT documents: 5 years from the end of the business relationship (Article L.561-12 of the French Monetary and Financial Code);
• Accounting and financial data: 10 years (Article L.123-22 of the French Commercial Code);
• Trading and performance data: duration of the Funded Account + 3 years;
• Browsing data and technical logs: a maximum of 13 months (CNIL recommendation);
• Marketing data (with consent): 3 years from the last contact or until consent is withdrawn;
• Data relating to disputes: duration of the proceedings + the applicable statutory limitation period.

At the end of these periods, your data will either be securely deleted or irreversibly anonymised for statistical purposes.

Article 6 - Data Security

TickWise implements appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or unauthorised access. These measures include, in particular:

• Encryption of data in transit (TLS/HTTPS protocol) and at rest;
• Strict access controls based on the principle of least privilege;
• Secure servers and application firewalls;
• Continuous monitoring of systems to detect vulnerabilities;
• Procedures for managing security incidents and notifying personal data breaches, in accordance with Articles 33 and 34 of the GDPR (notification to the CNIL within 72 hours in the event of a breach presenting a risk).

Although we endeavor to implement security measures that comply with industry standards, no transmission system over the Internet can be guaranteed to be completely secure. Accordingly, we cannot guarantee the absolute security of personal data, and any transmission of data is carried out at your own risk.

Article 7 - Minors

Our Services are not intended for persons under 18 years of age. We do not knowingly collect or process personal data relating to minors without the authorization of a parent or legal guardian.

If you believe that we have inadvertently collected personal data concerning a child without the appropriate consent, please contact us immediately at compliance@tickwisefunding.com. We will delete such data without undue delay.

Article 8 - Your Rights

In accordance with the GDPR (Articles 15 to 22) and the French Data Protection Act, you have the following rights concerning your personal data:

• Right of access (Article 15 GDPR):
  You may obtain confirmation as to whether we are processing personal data concerning you and request a copy thereof.
• Right to rectification (Article 16 GDPR):
  You may request the correction of inaccurate data or the completion of incomplete data.
• Right to erasure - “right to be forgotten” (Article 17 GDPR):
  You may request the deletion of your data in certain circumstances, in particular where the data are no longer necessary for the purposes for which they were collected, or where consent has been withdrawn.
• Right to restriction of processing (Article 18 GDPR):
  You may request the temporary suspension of the processing of your data in certain cases.
• Right to data portability (Article 20 GDPR):
  You may request to receive your data in a structured, commonly used and machine-readable format, and to have it transmitted to another data controller.
• Right to object (Article 21 GDPR):
  You may object at any time, on grounds relating to your particular situation, to processing based on TickWise’s legitimate interest. You may also object at any time to the processing of your data for direct marketing purposes.
• Right to withdraw consent:
  Where the processing is based on your consent, you may withdraw it at any time, without affecting the lawfulness of processing carried out before such withdrawal.
• Post-mortem directives (Article 85 of the French Data Protection Act):
  You may establish directives concerning the retention, erasure and disclosure of your data after your death.

How can you exercise your rights?

To exercise any of these rights, please contact us at: compliance@tickwisefunding.com or by post at the following address: TICKWISE, 173 rue de Courcelles 75017, Paris, France.

We may ask you to provide proof of identity before processing your request. We will respond within one month of receiving your request; this period may be extended by an additional two months in the event of a complex or numerous request (with notification within the first month).

Right to lodge a complaint with the CNIL

If you consider that the processing of your personal data does not comply with the applicable regulations, you have the right to lodge a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL):

• Website: www.cnil.fr
• Address: 3 place de Fontenoy - TSA 80715 - 75334 Paris Cedex 07
• Telephone: 01 53 73 22 22

Article 9 - Cookies and Similar Technologies

Our Website and our Platform use cookies and similar technologies. For detailed information on the types of cookies used, their purposes, retention periods and the management of your preferences, please consult our Cookie Policy available on the Website.

In accordance with the recommendations of the CNIL, no cookie that is not strictly necessary is placed without your prior consent, collected through our cookie preference management tool.

Article 10 - Social Media and External Links

Our Website or our Platform may include links to, or integrations with, social media platforms such as Facebook, Instagram, LinkedIn or X (Twitter). When you interact with these third-party services, the processing of your personal data is governed exclusively by the privacy policies of the providers concerned.

We disclaim any liability for the collection, processing or use of data carried out by such third parties, and encourage you to consult their privacy policies before interacting with them.

Our Services may also display links to external websites. Your use of such websites is governed by their own terms and conditions and privacy policies, and we disclaim any liability for their practices.

Article 11 - Marketing and Commercial Communications

With your prior consent, we may send you commercial communications by email, SMS or notification concerning our Services, offers and news.

You may unsubscribe at any time:

• By clicking the unsubscribe link included in each commercial email;
• By modifying your preferences in your customer account;
• By contacting us directly at compliance@tickwisefunding.com.

Withdrawal of your consent does not affect the lawfulness of processing carried out before such withdrawal. We will cease sending you commercial communications within a reasonable period following your request.

Article 12 - Automated Decision-Making and Profiling

As part of monitoring performance and detecting Prohibited Practices on the Platform, TickWise may use automated trading data analysis systems. Such automated processing may have significant effects on your access to the Services (suspension, termination).

In accordance with Article 22 of the GDPR, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. In such cases, you have the right to obtain human intervention from TickWise, to express your point of view and to contest the decision by contacting support@tickwisefunding.com.

Article 13 - Amendments to the Privacy Policy

We may update this Privacy Policy at any time to reflect legal, regulatory or operational developments. The date of the last update is indicated in the document header.

The updated versions will be published on the Website, with the revision date clearly indicated. In the event of a material amendment affecting your rights, we will inform you by email or by notification on the Platform before the new provisions enter into force.

Continued use of the Services after publication of the updated Privacy Policy shall constitute acceptance of the new provisions, to the extent permitted by applicable law.

Article 14 - Contact

For any questions relating to this Privacy Policy or the processing of your personal data:

• Email: compliance@tickwisefunding.com
• Website: https://tickwisefunding.com
• Postal address: TICKWISE, 173 rue de Courcelles 75017, Paris, France

No DPO has been designated at this stage. Please contact compliance@tickwisefunding.com for any questions relating to personal data.