Privacy Policy

At Thndr, we take privacy and security seriously. This Privacy Policy outlines how Axis Markets B.V., and its subsidiaries (collectively, the “Company,” “Thndr,” “we,” “our,” or “us”) process the information we collect about you through our websites, mobile apps, and other online services (collectively, the “Services”) and when you otherwise interact with us, such as through our customer service channels.

1. TYPES OF INFORMATION COLLECTED AND HOW WE COLLECT THEM
Personal Information You Provide:
We collect the following personal information you provide when you use our Services, like when you sign up for an account, request a transaction, enroll in a promotion or program, or otherwise engage or communicate with us:

• Identity Data includes your full name, date of birth, gender and other data on government-issued identification documents

• Contact Data includes your email address, home address, and telephone numbers

• Financial Data includes your bank account and payment card details, and information about your income and account balances

• Profile Data includes your username and password, purchases or orders made by you, your knowledge assessment results, and your interests, preferences, feedback, and survey responses

• Usage Information includes information about how you access and use our Services, such as your actions on the Services, including your interactions with others on the Services, photos or media you upload to the Services, and other content you provide (“Usage Information”). We only access your device camera roll and camera with your permission. If you need to update your permissions, you can do so in your device’s settings. Please remember that Thndr may, but has no obligation to, monitor, record, and store Usage Information in order to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, to protect and defend our rights and property, or for other reasons relating to our provision of the Services. By using the Services, you consent to the recording, storage, and disclosure of such information you send or receive for these purposes.

• Contact List Information with your permission, we may access your contact list on your mobile device or in your email accounts so that you can identify your contacts on the Services and direct the invitation of your contacts. We store and use this information to suggest referrals or connections and for other reasons related to our provision of the Services. We make these recommendations based on your contact list information as well as, with their consent, your contacts’ information if they are also a Thndr customer. We only access your contact list information with your explicit permission. If you provide us with personal data from your third-party contacts, it is your responsibility to ensure that the communication of such data to, and further processing by, Thndr is lawful. For example, when you provide us with information about your contacts, we may use it to let you know which of your contacts have also signed up for our Services or, at your exclusive direction, send messages to your contacts regarding our Services. We will not send messages to your contacts that are not explicitly directed by you.

• Additional Information includes information that you submit via focus groups, contests/sweepstakes, job applications, customer support, or other similar means. We may also collect any communications between Thndr and you (including recording calls made to or by Thndr) and any other information you provide to Thndr.

Personal Information Collected Automatically:
As is true of many digital platforms, we collect certain personal information automatically when you visit our online services, including:

• Location Data To help us protect against fraud, provide our services to you, and improve our services, we collect location data, including current and historical information concerning a user’s geographic location, GPS location, transaction location, and IP addresses that they use in conjunction with our Services. We collect your precise location data with your permission, and use that information, for example, to help protect against fraud by detecting and declining debit card transactions that may occur far away from your device’s location. We collect information about your location through GPS, Wi-Fi, wireless network triangulation, or other methods in order to obtain your location. We may also approximate your location by your IP Address. We also use the Google Maps API to gather information about your location. Google uses various technologies to determine your location, including IP address, GPS, and other sensors that may, for example, provide Google with information on nearby devices, Wi-Fi access points, and cell towers (see Google’s Privacy Policy to learn more).

• Usage and Device Data Collected Automatically Through Tracking Technologies To provide a personalized and enhanced user experience, we, and our third-party partners, automatically collect certain types of usage information when you visit or use our Services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, Flash objects, web beacons, embedded scripts, location identifying technologies, file information, and similar technology (collectively, “Tracking Technologies”). For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID (that allows us to uniquely identify your browser, mobile device, or your account), and other similar information. We use Tracking Technologies to help ensure that you have a high-quality experience on our Services. We also use Tracking Technologies to aid in the targeted advertising of our services on other platforms. From your device manufacturer, we also may collect the names of other third-party applications that you have downloaded on your device.

Our Services also occasionally use “local shared objects” (also known as “Flash cookies”). Like browser cookies, Flash cookies may be used for coordinating content delivery, website functionality, maintaining preferences, advertising, or analytics. Unlike browser cookies, “Flash cookies” are not stored in the browser.

Personal Information from Other Sources and Third Parties:
We also obtain personal information from other sources, which we often combine with personal information we collect either automatically or directly from you.

• Third-party Data includes data that we collect from business partners, marketing, and vendor partners

• Third Party Services If you link, connect, or log in to your Thndr Account with a third party service (e.g. Google, Facebook), the third-party service may send us information such as your profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service

• Publicly Available Data includes contact information, employment-related information, and other information from publicly available sources. We may combine this information with the information we collect from you directly. We use this information to contact you, to send you advertising or promotional materials, to personalize our Services, and to better understand the demographics of our users.

2. HOW WE USE YOUR INFORMATION
Personal Information You Provide:
We collect the following personal information you provide when you use our Services, like when you sign up for an account, request a transaction, enroll in a promotion or program, or otherwise engage or communicate with us:

• Create and process your account and deliver the Services to you including to allow you to register for the Services and participate in interactive features and for Thndr to authenticate your identity, handle billing and account management, fulfill our legal and regulatory obligations and complete other administrative matters

• Send you transactional information including confirmations, invoices, technical notices, product and services information and announcements, software updates, security alerts, support and administrative messages, and information about your transactions with us

• Communicate with you such as to respond to your comments and questions, deliver newsletters or other content we believe you will be interested in, provide customer service or feedback, contact you about amounts owed, conduct surveys, notify you about upcoming events, or for any other purposes in connection with the Services

• Conduct research and analytics to understand our visitors and customers and tailor our product offerings

• Provide you with updates about products and services offered by us and selected partners, as well as facilitate new contests, sweepstakes, promotions, and rewards.

• Make suggestions and recommendations to you about things that are similar to those about which you have inquired or that may otherwise be of interest to you, such as providing you with advertisements based on your interests and activity on the Services

• Monitor, administer, and enhance our Services including troubleshooting, data analysis, testing, research, statistical, and survey purposes

• Enhance the safety and security of our Services, business, and users, and investigate or provide notice of fraud or unlawful or criminal activity

• Perform audits and protect or exercise our legal rights or defend against legal claims, including to enforce and carry out contracts and agreements

• Comply with applicable laws and legal obligations

3. DISCLOSURES OF PERSONAL INFORMATION
We are committed to maintaining your trust, and we want you to understand when and with whom we may share the personal information we collect. We may share your personal information in the instances described below. For further information on your choices regarding your personal information, see the “Control Over Your Information” section below. We do not sell or rent your personal information to third parties, aside from substantial corporate transactions (described below).

• Authorized third-party vendors and service providers We share personal data with certain authorized and vetted contractors, subcontractors, third-party vendors, and service providers who help us run and protect our business. This includes sending emails, conducting business analytics, marketing, and data processing. For example, we may share personal data with service providers that identify and serve targeted advertisements or provide mailing services, tax and accounting services, contest fulfillment, web hosting, or analytics services

• Companies in which you hold securities Thndr may provide your name, address, and securities positions to requesting companies in which you hold securities.

• Thndr subsidiaries We share personal data with companies owned or controlled by Axis Markets B.V. including Axis Technology LLC, Thndr Securities Brokerage, Thndr Financial Ltd, Thndr Technology Holding and Axis Middle East FZE. These companies will use your personal information in the same way that we do under this Privacy Policy.

• Substantial corporate transactions We may share personal data in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, reorganization, financing, change or control or acquisition of all or a portion of our business by another company or third party, asset sale, initial public offering, or in the unlikely event of bankruptcy or similar proceeding.

• Legal purposes We disclose personal data to respond to court orders, legal process, law-enforcement requests, legal claims, or government inquiries and to protect and defend the rights, interests, safety, and security of Thndr, our affiliates, users, or the public.

• With your consent We share personal data for any other purposes disclosed to you with your consent.

4. THIRD-PARTY LINKS
Some of the Services may contain links to content maintained by third parties that we don’t control. We’re not responsible for the privacy practices of these third parties or the content on the third party services, and the information practices of these third parties are not covered by this Policy. Please note that these third-party services have their own privacy policies, and we strongly recommend that you read their privacy policies as well as terms and conditions of use to understand how they collect, use, and share your information.

5. THIRD-PARTY TRACKING AND ONLINE ADVERTISING
We participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your online browsing history and your interests. We do not advertise on behalf of specific securities or investment options on our Services. We permit third-party online advertising networks, social media companies, and other third-party services to collect information about your use of our Services over time so that they may play or display ads on other websites, apps, or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. For advertising, we may share a common account identifier (such as an email address or user ID) or hashed data with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online on other platforms more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. We’re not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Policy.

Google Analytics and Advertising We use Google Analytics to recognize you and link your devices and when you use our Services on your browser or mobile device, log in to your account on our Services, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the Services. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you. We may also use certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features let us use first-party cookies and third-party cookies together to inform, optimize, and display ads based on your use of our Services.

6. CONTROL OVER YOUR INFORMATION


• Account profile You may update certain elements of your account profile information by logging into your account.

• Access to your device data You may control the mobile app’s access to your device information in your device’s settings

• How to control your communications preferences. You can stop receiving promotional emails from us by clicking on the provided “unsubscribe” link. You may not opt out of service-related or other non-promotional communications (e.g., account verification, transactional communications, changes/updates to features of the Services, and technical and security notices).

7. TRANSFER OF PERSONAL INFORMATION
Our Services are currently designed for use only in certain select markets. If you are using our Services from another jurisdiction, your information collected through our Services may be stored and processed in Egypt, Netherlands, United Arab Emirates or any other country in which Thndr maintains facilities or conducts business activities. If you are located in other regions with laws governing data collection and use that may differ from our local laws, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data-protection laws as your jurisdiction.

8. USER DATA DELETION
We retain your personal information in an identifiable form in accordance with our internal policies, which establish general standards and procedures regarding the retention and handling of your personal information. Personal Information is retained for as long as necessary to meet legal, regulatory and business requirements. We allow users to request that we erase their personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally required to retain it.

9. CHANGES TO THIS POLICY
This Privacy Policy will evolve with time. To stay informed of our privacy practices, we recommend you review the Policy on a regular basis as you continue to use our Services.

10. HOW TO CONTACT US
If you have any questions about this Privacy Policy or the Services, please contact us at support@thndr.app