Privacy Policy

1.1 This Privacy Policy explains how NAMH Global Ltd ("NAMH", "we", "us", "our") collects, uses, shares and keeps personal data about you. In this policy, "you" means a visitor to our Website, a person who applies for an Account, a Client, or a person who applies to be an introducing broker or affiliate ("partner"). Other capitalised words, such as Account, Client Portal and Website, have the meaning given in clause 1.5 of our Terms of Service.

1.2 It covers personal data we handle through the Website, the Client Portal, our MT5 trading accounts, our support channels and our partner programmes (together, the "services").

1.3 NAMH Global Ltd is a company registered in Saint Lucia (No. 2024-00372). It is the data controller for the personal data described in this policy. This means it decides why and how that data is used.

1.4 NAMH Global Ltd is not licensed by a securities regulator.

1.5 Our services are not available to residents of the United States, the United Arab Emirates, India, Iran, Cuba, Iraq, Myanmar, North Korea or Sudan (the Restricted Jurisdictions in Section 12 of our Terms of Service). If you live in one of these places, do not apply for an Account.

1.6 Our Cookie Policy explains the cookies and similar tools on the Website. It forms part of this policy.

1.7 For privacy questions or requests, write to support@namhglobal.com with the subject line "Privacy request" (see clause 12).

1.8 This policy is a notice about how we handle personal data. It is not part of the client agreement described in clause 1.4 of our Terms of Service, and we can update it as clause 11 describes.

2.1 Identity and verification data. Your full name, date of birth, nationality and residential address. A copy of a government-issued ID (passport, national ID card or driving licence). A proof-of-address document (for example a utility bill or bank statement), where we ask for one. Where our verification process asks for one, a photo or video of you (a "selfie") that is compared with your ID. A tax identification number, where we need it.

2.2 Contact data. Your email address and telephone number.

2.3 Financial and account data. Your Account details, balances, positions, orders and trading history. Your deposits and withdrawals. Payment details for the method you use (card, bank wire, crypto or e-wallet). For cards we keep a limited reference, such as the last four digits. Information about the source of your funds and your wealth, when we ask for it.

2.4 Technical and usage data. IP address, device type, browser and operating system. Pages you visit on the Website. Log-in times and activity in the Client Portal and MT5. Data collected through cookies and similar tools, as explained in our Cookie Policy.

2.5 Communications data. Emails, chat messages, messages through WhatsApp or Telegram, and other correspondence with us. Recordings of telephone calls, where we record them and the law allows it. Survey answers and feedback.

2.6 Partner data. If you apply to be a partner: your name, email address, telephone number, the information in your application, and the details we need to calculate and pay your rebates or commissions.

2.7 Marketing preferences. Whether you have agreed to receive marketing from us, and your newsletter subscription.

2.8 Where the data comes from.

• (a) From you: when you register, verify your identity, fund your Account, contact us, fill in a form on the Website, or apply to be a partner.
• (b) Automatically: when you use the Website, the Client Portal or MT5 (see clause 2.4).
• (c) From others: identity verification and screening providers, fraud-prevention services, payment providers, and the partner who introduced you to us (if any).
• (d) From public sources: sanctions lists, lists of politically exposed persons, and other publicly available records we check for compliance.

3.1 We use personal data only for the purposes below.

• (a) To provide the services: to open and run your Account, carry out your orders, process deposits and withdrawals, and give you support.
• (b) To meet legal duties: to verify your identity, screen against sanctions and politically exposed person lists, monitor transactions for money laundering and fraud, keep records, and answer lawful requests from authorities.
• (c) To keep accounts and systems secure: to prevent fraud and misuse, protect your Account, and investigate and respond to incidents.
• (d) To communicate with you: to send confirmations, Account and service notices, replies to your questions, and notices we must give you by law.
• (e) To run our partner programmes: to link a client to the partner who introduced them, and to calculate and pay partner rebates and commissions.
• (f) To improve the Website and services: to understand how they are used and fix problems.
• (g) For marketing: to send you newsletters, market updates and offers, and to measure our advertising. We do this only with your consent (see clauses 3.2 and 3.3).

3.2 You can stop marketing emails at any time with the unsubscribe link in each email, or by writing to support@namhglobal.com. Service and legal notices are not marketing, and we will keep sending them while you have an Account.

3.3 Advertising and analytics tools on the Website, such as the Meta Pixel and Google Tag Manager, run only if you click Accept all in our cookie banner. The Meta Pixel lets Meta link your visit to ads you have seen. If we add Google analytics or advertising tags, they also run only after you accept. Our Cookie Policy explains this and how to change your choice.

4.1 Where a data-protection law that applies to you requires us to have a legal basis, we rely on the following:

• (a) Contract: the use is needed to provide the services you ask for, or to take steps before you open an Account.
• (b) Legal obligation: the use is needed to meet anti-money-laundering, sanctions, tax, record-keeping or other legal duties.
• (c) Legitimate interests: the use is needed for fraud prevention, security, running our partner programmes, and improving the services. We use data this way only where our interests are not outweighed by your rights.
• (d) Consent: for marketing, and for analytics and advertising cookies on the Website. You can withdraw consent at any time. This does not affect anything we did before you withdrew it.

5.1 We share personal data only as far as each recipient needs it for the purposes in clause 3. Recipients fall into these groups:

• (a) The partner who introduced you. If you opened your Account through an introducing broker or affiliate, that partner can see, in our partner portal, your name, your country, the date you joined, your Account status, the total amount you have deposited, and how much you trade (in lots). They see this so that they can be paid their rebate or commission. They do not see your identity documents.
• (b) Payment providers: card processors, banks, crypto payment providers and e-wallet providers, to process your deposits and withdrawals.
• (c) Identity verification and screening providers: to check your identity and documents and to screen against sanctions and politically exposed person lists.
• (d) MetaQuotes, the developer of the MetaTrader 5 platform, as the provider of the trading platform software and the MT5 apps you use to trade.
• (e) Banks and liquidity providers we use to settle payments and manage our trading risk, to the extent they need the data.
• (f) Technology providers: the providers of our client-relationship (CRM) and Client Portal software and the people who support it, our hosting and cloud providers, and our email provider (used to send emails and to handle newsletter sign-ups, Website contact forms and partner applications).
• (g) Advertising, analytics and reviews providers: Meta (Facebook, Instagram) and Google, and Trustpilot for the reviews widget on our homepage, for Website visitors who accept these tools in our cookie banner. See our Cookie Policy.
• (h) Messaging services: if you contact us through WhatsApp, Telegram or a similar service, that service handles your messages under its own terms.
• (i) Professional advisers: lawyers, accountants and compliance consultants who owe us a duty of confidentiality.
• (j) Authorities: courts, law enforcement agencies, financial intelligence units, tax authorities and other public bodies, where the law requires or allows us to disclose data.
• (k) A buyer or successor: if all or part of our business is sold, merged or transferred, the new owner, who must protect the data to the same standard.

5.2 We require our service providers to use your data only to provide their service to us, and to keep it confidential.

5.3 We do not sell your personal data.

6.1 The Website and the Client Portal use encrypted connections (HTTPS).

6.2 Only staff and contractors who need personal data for their work can access it.

6.3 No system is completely secure. If a security breach affecting your personal data is likely to put you at risk, we will tell you without undue delay and explain what you can do. We will also tell any authority we are required to tell.

6.4 Keep your passwords private. Tell us at once at support@namhglobal.com if you think someone else has used your Account.

7.1 We keep personal data only as long as we need it for the purposes in clause 3, or as long as the law requires.

7.2 In particular:

• (a) Identity, verification and Account data, and records of your transactions: at least 5 years after your Account is closed (or our relationship with you otherwise ends), or longer where the law requires.
• (b) Records of our communications with you: as long as we keep the Account records they relate to, or longer if they are needed for a complaint, dispute or legal claim.
• (c) Marketing data: until you withdraw consent or unsubscribe. We then keep a record that you opted out, so that we do not contact you again.
• (d) Website and system logs: as long as needed for security and troubleshooting.
• (e) Applications that do not lead to an Account, and partner applications that we decline: as long as needed to deal with the application and to meet our legal duties.

7.3 When the retention period ends, we delete the data or make it anonymous.

8.1 Depending on the law that applies to you, you may have the right to:

• (a) get a copy of the personal data we hold about you;
• (b) have inaccurate or incomplete data corrected;
• (c) have your data deleted, unless we must keep it by law (see clause 7);
• (d) ask us to limit how we use your data in certain cases;
• (e) receive data you gave us in a machine-readable format, or have it sent to another company;
• (f) object to our use of your data based on legitimate interests, and to direct marketing at any time;
• (g) withdraw consent you have given; and
• (h) complain to the data-protection authority where you live.

8.2 To use any of these rights, write to support@namhglobal.com with the subject line "Privacy request". We may ask you to prove your identity before we act.

8.3 We will reply within 30 days. If a request is complex, we may need longer. If so, we will tell you within the 30 days and explain why.

8.4 If we cannot do what you ask, for example because the law requires us to keep the data, we will tell you why.

9.1 Our service providers and partners may be in countries other than the one where you live. Data-protection laws in those countries may differ from yours.

9.2 When we send personal data to another country, we send only the data the recipient needs. Where the law that applies to you requires specific safeguards for the transfer, we use a safeguard that law allows, such as standard contractual clauses.

10.1 Our services are only for adults: people who are at least 18 years old, or the age of majority where they live if that is higher. We do not knowingly collect personal data from children. If you believe a child has given us personal data, contact support@namhglobal.com and we will delete it.

11.1 We may change this policy when our services, our providers or the law change.

11.2 We publish every change on this page with a new version number and effective date. If a change is material, we will email Account holders at least 14 days before it takes effect.

11.3 Earlier versions are available on request.

12.1 For privacy questions and requests:

• Email: support@namhglobal.com (subject: "Privacy request")
• Phone or WhatsApp: +1-758-461-4088
• Support is available 24 hours a day, 7 days a week.

12.2 Data controller: NAMH Global Ltd, a company registered in Saint Lucia (No. 2024-00372). We will give you our postal address on request.