Data processing

Ocean Capital Exchange and its Group Companies (“we” or ”us”) are committed to processing your Personal Data in accordance with applicable law. This Data Processing Policy (the “Policy”) will apply when, and to the extent that, we act as a Data Processor for you.

Capitalized terms that are not defined in the body of this Policy are defined in Exhibit 1 to this Policy.

1.COMPLIANCE WITH DATA PROTECTION LEGISLATION.

Regulatory Information

Ocean Capital Exchange Ltd is a company registered in England and Wales (registered no. 10659900). Registered office: 8 Twisleton Court Priory Hill, Dartford DA1 2EN. Ocean Capital Exchange Foreign Exchange and Payment services are provided by 4 partners. Ocean Capital Exchange Ltd’s Payment and Foreign Currency Exchange services are provided by Ebury Partners UK Limited. Ebury Partners UK Limited is authorised and regulated by the Financial Conduct Authority as an Electronic Money Institution. Reference Number: 900797. Ebury Partners UK Limited is registered with the information Commissioner’s Office under the UK Data protection Act (registered no. Z209673X). Ocean Capital Exchange Ltd is a Programme Manager of Ebury Partners UK ltd – registered in England and Wales, registration number 7088713 Registered office: 3rd floor, 100 Victoria Street, Cardinal Place, London, SW1E 5JL. Payment services (Non MIFID related products, non-e-commerce accounts, non-lending products, non-trade finance products) for Ocean capital exchange are provided by The Currency Cloud Limited. Registered in England No. 06323311. Registered Office: Stewardship Building 1st Floor, 12 Steward Street London E1 6FQ. The Currency Cloud Limited is authorised by the Financial Conduct Authority under the Electronic Money Regulations 2011 for the issuing of electronic money (FRN: 900199). For clients based in the European Economic Area, payment services for Ocean Capital Exchange Ltd are provided by CurrencyCloud B.V.. Registered in the Netherlands No. 72186178. Registered Office: Nieuwezijds Voorburgwal 296 – 298, Mindspace Nieuwezijds Office 001 Amsterdam. CurrencyCloud B.V. is authorised by the DNB under the Wet op het financieel toezicht to carry out the business of an electronic-money institution (Relation Number: R142701). For clients based in the United States, payment services for Ocean Capital Exchange Ltd are provided by The Currency Cloud Inc. which operates in partnership with Community Federal Savings Bank (CFSB) to facilitate payments in all 50 states in the US. CFSB is registered with the Federal Deposit Insurance Corporation (FDIC Certificate# 57129). The Currency Cloud Inc is registered with FinCEN and authorised in 39 states to transmit money (MSB Registration Number: 31000206794359). Registered Office: 104 5th Avenue, 20th Floor, New York , NY 10011. For clients based in the United Kingdom and rest of the world, payment services (Non MIFID related products) for Ocean Capital Exchange Ltd are provided by The Currency Cloud Limited. Registered in England and Wales No. 06323311. Registered Office: Stewardship Building 1st Floor, 12 Steward Street London E1 6FQ. The Currency Cloud Limited is authorised by the Financial Conduct Authority under the Electronic Money Regulations 2011 for the issuing of electronic money (FRN: 900199).  FX and payments provided by GC Partners. Global Currency Exchange Network Limited T/A GC Partners is authorised by the FCA under the Payment Services Regulations, 2017. Registration number 504346. Global Currency Exchange Network Limited T/A GC Partners is registered with HMRC under the Money Laundering Regulations, 2017. Registration number 12137189. Payment services for Ocean Capital Exchange are provided by Equals Connect Limited, a company incorporated in England & Wales Registration No : 07131446. Equals Connect Limited is licensed and regulated by HMRC as a Money Service Business (MSB) Licence No : 12594438. Equals Connect Limited is authorised by the Financial Conduct Authority as an Authorised Payment Institution Firm Reference Number : 671508.