Last Updated: May 26, 2025

Thank you for your interest in Markets DNA Ltd. (“Markets DNA”, “we”, “our”, or “us”). We take your privacy and data protection seriously. This Privacy Policy explains how we collect, process, and protect your personal data when you visit our website or interact with our services.

1. Data Controller

Markets DNA Ltd.

2967 Dundas West Street, Suite 176d, Toronto, ON, M6P1Z2, Canada

Email: privacy@marketsdna.com

2. Scope of This Policy This Privacy Policy applies to all visitors and users of our website [marketsdna.com] and all associated domains, systems, and platforms directly managed by us.

It governs the handling of personal data in accordance with the General Data Protection Regulation (GDPR), Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), and other relevant international data protection laws.

3. Data We Collect We only collect data that is necessary to:

• Evaluate potential collaboration

• Provide infrastructure-related services

• Fulfill legal or regulatory requirements

The types of personal data we may collect include:

• Full name

• Email address

• Company name

• Country of operation

• Professional profile or role

• Communication content

• IP address and browser data (minimally, and only when technically required)

We do not use tracking cookies, pixel-based retargeting, or third-party analytics tools.

4. Purpose of Processing We process your data solely for the following purposes:

• To assess your application or inquiry

• To provide support and infrastructure access (where agreed)

• To maintain our internal client records

• To fulfill legal obligations

5. Legal Basis for Processing Our data processing is based on:

• Your explicit consent (Art. 6(1)(a) GDPR)

• Pre-contractual or contractual necessity (Art. 6(1)(b) GDPR)

• Our legitimate interest in building secure infrastructure (Art. 6(1)(f) GDPR)

• Compliance with legal obligations (Art. 6(1)(c) GDPR)

6. Data Retention We store your data only for as long as necessary:

• To fulfill the purpose of collection

• To meet legal retention periods (e.g., accounting or regulatory compliance)

You may request deletion at any time unless otherwise required by law.

7. Data Sharing Markets DNA does not share, rent, or sell your data to third parties.

Your data will only be shared:

• Internally, among authorized team members

• With legal authorities, when obligated

• With infrastructure service providers, only where necessary and under strict confidentiality agreements

All third-party vendors are contractually obligated to comply with data protection standards.

8. Data Transfers Outside Canada If data is transferred outside Canada (e.g., to the EU or USA), we ensure equivalent data protection safeguards, including:

• Standard contractual clauses (SCC)

• Adequacy decisions

• Binding corporate rules (where applicable)

9. Your Rights You have the right to:

• Access your personal data

• Request correction or deletion

• Withdraw consent

• Object to processing

• File a complaint with the appropriate data protection authority

To exercise your rights, please contact: privacy@marketsdna.com

10. Data Security We implement appropriate technical and organizational measures to protect your data, including:

• Encrypted databases

• Access restrictions

• Audit logs and security monitoring

11. Children’s Data Our services are not directed at individuals under the age of 18. We do not knowingly collect data from minors.

12. Updates to This Policy We may revise this Privacy Policy to reflect changes in law or internal practices. Any updates will be posted at [marketsdna.com/legal#privacy] and marked with a new “Last Updated” date.

For questions or concerns about this policy, contact us at:

privacy@marketsdna.com