Introduction

This privacy notice ("Policy") applies to your use of all the mobile applications, products, software, services, websites, publications, email subscription and the content thereof, other services, and your relationship with us (collectively, the "Service") operated by O'Cof Securities Limited ("we", "us" or "our").

We are subject to data protection requirements in the jurisdictions where our enterprises are incorporated. This policy outlines what information we collect, how we use it, how we process it, how we disclose it, and your rights in relation to that information.

Table of Contents

• 1. What Information Do We Collect?
• 2. How Do We Use Your Information?
• 3. Will Your Information Be Shared With Anyone?
• 4. Who Will Your Information Be Shared With?
• 5. How Long Do We Keep Your Information?
• 6. How Do We Keep Your Information Safe?
• 7. What Are Your Privacy Rights?
• 8. Do We Make Updates To This Policy?
• 9. How Can You Contact Us About This Policy?

1. What Information Do We Collect?

Personal Information You Provide

• Full name, email, phone number, address, date of birth
• Employment status, source of wealth, tax ID
• Passport or ID card number and image, selfie
• Trusted contact's name and email
• Written communication and support documents
• Account credentials and contact list (for gifting features)

Automatically Collected Information

• Device/browser data, IP address, location
• Transaction history, usage logs
• Cookies and push notifications

Third-Party Sources

• Public databases, eKYC providers, marketing leads, social profiles

2. How Do We Use Your Information?

• Account management, risk assessment, admin, customer service
• Marketing and promotions (with consent)
• Legal compliance, security, and fraud prevention
• Product improvements, analytics, and advertising
• Responding to legal requests and enforcing terms

3. Will Your Information Be Shared?

• With your consent
• For legal obligations or to protect rights
• For legitimate business needs
• With vendors, service providers, legal counsel
• During business transfers or mergers

4. Who Will Your Information Be Shared With?

• Internal departments and affiliates
• Infrastructure and marketing tools (AWS, Google, MailChimp, Twilio, etc.)
• Regulatory bodies, fraud prevention, credit agencies
• Service providers for custody, clearing, remittance, analytics

Some may reside outside The Bahamas. Your data may be transferred internationally.

5. How Long Do We Keep Your Information?

• As long as necessary for business or legal reasons
• Up to 7 years after account termination (unless otherwise required)

6. How Do We Keep Your Information Safe?

• Technical and organizational safeguards
• Controlled access and secure environments
• Breach notifications within 14 days if required by law

7. What Are Your Privacy Rights?

• Access, modify, or delete account data
• Unsubscribe from marketing
• Opt out of behavioral advertising

If you suspect a violation, contact support@prospuh.com — we will respond within 21 days.

8. Do We Update This Policy?

Yes. We may revise it to stay compliant with laws. Updates are posted on the Service and may also be sent via email.

9. How to Contact Us?