1. Purpose of the Document

1. This document (hereinafter — "Policy") defines the mechanisms for protecting personal data from unauthorized access by Foresight FX LLC (hereinafter — "Currency Exchange Point", "Company").
2. The Policy defines the basis and purpose for which clients' personal data is collected and processed, and how it is protected taking into account legal and technical aspects.
3. The Policy applies to persons (both Company clients and non-clients) who provide personal information to the Company or use the Company's website.
4. By registering on the website and/or application of Foresight FX LLC and/or using our products and services, the Client agrees to the collection and use of personal data about them in accordance with this Privacy Policy.

2. Definitions

1. Currency Exchange Point — the company "Foresight FX" (ID: 404789644) registered by the National Bank of Georgia, which provides currency conversion services in accordance with Georgian legislation, in non-cash form through the platform — www.fxhub.ge.
2. Client/User — an individual, individual entrepreneur, legal entity, or organizational formation that carries out a currency exchange operation through the website.
3. Personal data — any information that relates to an identified or identifiable individual.
4. Biometric data — data processed using technical means, related to the physical, physiological, or behavioral characteristics of the data subject.
5. Data processing — any action performed on data, including its collection, acquisition, access, organization, storage, modification, use, deletion, or destruction.
6. Data subject — any individual whose data is being processed.

3. Personal Information Collected About the Client

1. In the course of its business activities, the Company collects information exclusively for purposes related to currency conversion services.
2. In the course of its activities, the Company receives the following types of information about data subjects:
   • Identification data — first name, last name, personal identification number.
   • Contact information — phone number, email address.
   • Information about bank account numbers used by the user for currency conversion services.
   • Audio monitoring/hotline telephone conversation recordings.
   • Correspondence conducted through online chat, message fields, and/or social networks posted on the website and/or application.
   • Data about technological devices — IP address, cookies, application logs.
   • Data required to be processed by legislation — obligations under the Georgian Law on "Facilitating the Prevention of Money Laundering and Terrorism Financing."

4. Basis and Purpose of Data Processing

1. The Company processes data when a corresponding basis exists:
   • The data subject has given consent;
   • Data processing is necessary for providing services;
   • Data processing is necessary for fulfilling obligations assumed under a transaction;
   • The corresponding data processing is provided for by law.
2. The Company collects personal information only from adults.
3. Data collection by the Company serves the following purposes:
   • The Company's legitimate business interests;
   • Facilitating the fight against fraud and money laundering;
   • Compliance with regulatory requirements;
   • Compliance with laws and regulations relevant to the Company;
   • Managing the risks of the Company and its clients;
   • Exercising rights and fulfilling obligations under the Agreement;
   • Conducting analysis and marketing activities;
   • Offering/providing Company services.
4. Sources for receiving client data by the Company include telephone communication, electronic inquiries, use of remote services, website usage, and office visits.
5. The Company uses Cookies to improve service quality and protect user security. For these purposes, the Company collects:
   • IP address, device type, operating system, and browser;
   • Information about pages opened on the website and session duration;
   • Information about actions taken on the website;
   • The process, time, and manner of filling in fields on the website;
   • Other information related to the website usage process.

The collected information enables the Company to adapt the website and its components to user needs. Cookies are also used to generate Google Analytics reports.

Before using the website, the Client has the opportunity to agree to the use of Cookies. If the Client wishes to restrict or block Cookie files, they can do so in their browser settings.

The Company may refuse to serve a Client if they decline to share personal information necessary for providing the service.

The Company undertakes that the Client's personal data will be reliably protected; the Client's personal data will not be used unlawfully.

To fulfill obligations under legislation or the Agreement, the Client's data may be shared with: the Client's representative, parties to the transaction, bodies designated by legislation, service providers (including: Company auditors, IT service providers, commercial banks/payment service providers).

5. Client Rights

1. The Client may request the correction, updating, addition, blocking, deletion, or destruction of personal data processed by the Company if they are incomplete, incorrect, or if their collection was carried out contrary to law. The Company will take appropriate actions within 10 (ten) business days of receiving such a request.
2. The Company operates in accordance with Georgian legislation, which may prevent the immediate deletion of the Client's personal data (anti-money laundering legislation, tax legislation).
3. The Company has the right to use personal data only when specific contractual and/or legal grounds exist.
4. The Client has the right to withdraw their consent at any time without explanation and request the cessation of data processing and/or the destruction of processed data. Within 10 (ten) business days of submitting the application.
5. Clients have the right to request the following information:
   • What rights the Client enjoys;
   • What constitutes the legal basis for data processing;
   • By what means their data was collected;
   • What types of data are processed about them;
   • What purpose data processing serves;
   • To whom and on what basis their data is transmitted;
   • For how long personal data is stored.

The Company is obligated to provide the Client with complete and accurate information immediately or no later than within 10 (ten) business days.

6. Storage of Personal Data by the Company

1. The Client's personal data is stored by the Company throughout the entire period of service, and in the event of termination of service, for 5 (five) years from the date of termination.
2. The Company may store the Client's data for more than 5 (five) years if their deletion is not possible due to legal and regulatory reasons.

7. Final Provisions

On any issue that may not be regulated by this document or is otherwise regulated by the Georgian Law on "Protection of Personal Data," the decision shall be made in accordance with the legislation in force in Georgia.