NOTICE TO INSTANT MESSAGE CONTACTS: Please note that SCB Group companies routinely record and retain Instant Message communications. These communications are then held for the security of all parties and will be used in the event of a dispute to ascertain facts.

NOTICE TO EMAIL RECIPIENTS:  Internet e-mail may be susceptible to data corruption, interception and unauthorized amendment for which SCB Group companies do not accept liability. Whilst SCB Group companies have taken reasonable precautions to ensure that e-mails and any attachments have been swept for viruses, SCB Group companies do not accept liability for any damage sustained as a result of viruses. Statements in e-mail messages or attachments that do not relate to the business of SCB Group companies are neither given nor endorsed by the Company or their Directors.

Please note that SCB Group companies reserve the right to intercept, monitor, and retain e-mail messages to and from their systems as permitted by applicable law. If you are not comfortable with the risks associated with e-mail messages, you may decide not to use e-mail to communicate with SCB Group companies but use alternative methods of communication.

SCB Group companies email policies do not require that "cc" recipients read or respond to an email. SCB Group companies policies are that "cc" recipients are being included either as a courtesy or to ensure a discussion is carried out in public or to give persons an opportunity to become involved in a discussion should they wish to do so.

NOTICE TO TELEPHONE CONTACTS: Please note that SCB Group companies routinely record telephone conversations on all lines. These conversations are then held for the security of all parties and will be used in the event of a dispute to ascertain facts.

NOTICE ON REGULATORY COMPLIANCE:

SCB & Associates Limited (United Kingdom) is authorised and regulated by the Financial Conduct Authority in the UK FRN: 592324

SCB Derivatives LLC (United States of America) is authorised and regulated by the National Futures Association in the USA: 0440120

SCB Brokers LLC (United States of America) is authorised and regulated by the National Futures Association in the USA: 0484646

SCB Brokers SA (Switzerland) is authorised and regulated by the National Futures Association in the USA: 0510531

Block Trades

Under CME, ICE and CFTC regulations, a broker negotiating a block trade on behalf of a customer may disclose the identity of the customer to potential counterparties only if the broker has received that party’s permission to do so. In many markets, it is common practice for market participants to disclose counterparty information. To avoid unnecessary delays in block trade execution, SCB will not seek permission to disclose counterparty information on a per trade basis in these markets. If a customer does not wish for its identity to be disclosed, it shall notify the broker.

Regulatory notice for Australian resident clients of SCB & Associates PTE (SCB)

SCB can only provide services to Australian resident clients that are "professional investors" within the meaning of that term in the Corporations Act 2001. SCB is exempt from the requirement to hold an Australian financial services licence in respect of the financial services which it provides to Australian resident clients. Accordingly, Australian resident clients will not have the benefit of the legislative protections that would apply if they were using the services of an Australian licensed entity.

NOTICE ON PRIVACY:

SCB ("We") are committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.starcb.com you are accepting and consenting to the practices described in this policy.

For the purpose of the EU General Data Protection Regulation Act of 2018 UK, (the Act), the data controller is SCB Brokers SA, Avenue de Perdtemps 17, CH 1260, Nyon, Switzerland

INFORMATION WE MAY COLLECT FROM YOU

We may collect and process the following data about you:

· Information you give us. You may give us information about you by filling in forms on our site www.starcb.com (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you use our site, our services, search for a product, participate in discussion boards or other social media functions via our site and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, personal description and photograph. If you make a job application via our site, you may need to provide information about your education, employment, region of interest and role you are applying for. Your application will confirm your express consent to our use of this information to assess your application and to allow us to carry out any monitoring activities which may be required of us under applicable law as an employer.

· Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

DISCLOSURE OF YOUR INFORMATION

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006, UK.
We may share your information with selected third parties including:

· Business partners, suppliers and sub-contractors for the performance of any contract we enter into with [them or] you.
We may disclose your personal information to third parties:

· In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

· If SCB or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

· If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or to protect the rights, property, or safety of SCB our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

WHERE WE STORE YOUR PERSONAL DATA

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

YOUR RIGHTS

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at SCBIT@starcb.com.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

ACCESS TO INFORMATION

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act.

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.

CONTACT

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to SCBIT@starcb.com.