1. Important Notice

This is the Privacy Policy for www.etfcircle.com (“ETF Circle”, “we”, “us”, “our”). It describes who we are, how we obtain and use your personal data, why we are allowed to do so by law, who has access to your personal data, and what your rights are. Please review it carefully.

Disclaimer: All content on www.etfcircle.com, including articles, news, reports, event materials, directory listings, job board content, and learning platform resources, is provided for informational and educational purposes only. We do not offer financial, investment, legal, or tax advice. Nothing on our site should be taken as a recommendation to buy, sell, or hold any security, asset, or financial product. You should always seek independent professional advice before making financial decisions.

This website is not intended for children, and we do not knowingly collect data relating to children.

You have the right to object to us processing your personal data for our legitimate business interests or for direct marketing purposes (including any related profiling).

2. What Personal Data We Collect & Why

Personal data is any information which identifies you personally whether directly (e.g., your name) or indirectly (e.g., information about your use of our products and services).

We may collect, store, and transfer different kinds of personal data about you, grouped as follows:

• Identity and Contact Data: includes first name, last name, email address, username, or similar identifier collected when you create an account, give feedback, leave a review, or participate in a prize draw, competition, promotion, or survey.
• Marketing and Communications Data: includes your preferences for receiving marketing from us and third parties, and your communication preferences.
• Technical Data: includes IP address, login data, and information about the devices, browsers, and technologies you use to access our website and/or app.
• Profile Data: includes username and password, your interests, preferences, feedback, and survey responses.
• Usage Data: includes information about how you use our website, app, products, and services.
• Correspondence: includes additional personal data you provide by email, letter, telephone, through our website or app (including messaging functionality), or other communication channels. Calls may be recorded for training, analytics, and dispute resolution purposes.

We also obtain personal data from other sources:

• Cookies and similar technologies: used to track your use of our website, provide functionality, monitor usage, personalize your experience, and deliver relevant advertising, including via Facebook pixels.
• Third parties: data received from third parties where you have given them consent to share your information with us.

3. How We Use Your Personal Data

We use your personal data for the following purposes:

• To provide and operate our services, including our financial news blog, job board, learning platform, events, and directory.
• To contact you in relation to competitions, prize draws, or promotions.
• Direct marketing — to send you information about products and services by email, SMS, post, or phone (including via trusted business partners, with your consent).
• Automated decision-making and profiling to tailor offers, recommendations, and services.
• Internal training of our staff to improve knowledge and customer service.
• Market research and analytics to better understand our audience and improve our products and services.
• Research and AI learning/training — to use data (in aggregated, anonymized, or pseudonymized form where possible) to train AI models, improve automated systems, and develop new technologies.
• Providing personalized content and recommendations based on your profile, interests, and behavior.
• To maintain records and ensure data accuracy.
• To respond to enquiries, complaints, and disputes.
• To detect, investigate, and prevent fraud, and to comply with our legal obligations.

4. Legal Grounds For Processing

We process your personal data under one or more of the following legal grounds:

• Consent — for sending marketing communications, conducting research, using your data for AI learning/training, and delivering personalized content.
• Performance of a contract — to deliver the services you sign up for.
• Legitimate interests — to improve our services, develop new offerings, conduct analytics, personalize experiences, and ensure efficient operations, provided these interests are not overridden by your rights.
• Legal obligations — to comply with laws and regulations, including fraud prevention.

5. Who We Share Your Personal Data With and Where It Is Stored

We may share your personal data with:

• Suppliers and service providers (including group companies) acting as processors on our behalf.
• Trusted business partners for marketing, analytics, research, and AI training purposes, where legally permitted.
• Research and technology partners for analytics and AI development (in aggregated or pseudonymized form where possible).
• Law enforcement agencies where required to comply with legal obligations.
• Successors in title or acquirers in the event of a merger, acquisition, or business transfer.

Some recipients may be located outside the European Economic Area (EEA). Where this is the case, we ensure that adequate safeguards are in place to protect your personal data.

6. How Long We Keep Your Personal Data For

We retain your personal data for no longer than necessary for the purposes for which it was collected, taking into account:

• legal obligations to retain data;
• statutory limitation periods;
• the resolution of disputes;
• guidance from data protection authorities.

Where possible, data used for research, AI learning/training, and analytics is anonymized or pseudonymized to minimize privacy risks.

7. Your Rights

Under data protection law, you have the right to:

• Receive clear and transparent information about how we use your data.
• Access your personal data.
• Request correction of inaccurate or incomplete data.
• Request deletion of your personal data where applicable (“right to be forgotten”).
• Restrict processing in certain circumstances.
• Obtain and reuse your personal data in a machine-readable format.
• Object to processing for legitimate interests or direct marketing (including profiling).
• Withdraw consent at any time where processing is based on consent.
• Lodge a complaint with the Information Commissioner’s Office (ICO) if you believe your data rights are being infringed.

8. How You Can Contact Us

To exercise your rights or raise concerns, you can:

• Email: info@etfcircle.com
• Use our Contact Us page on the website

If you are unsatisfied with our response, you can contact the ICO:

• Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
• Phone: 0303 123 1113
• Website: www.ico.org.uk

9. Links to Other Websites

Our website contains hyperlinks to websites owned and operated by third parties. This Privacy Policy does not apply to those sites, and we are not responsible for their privacy practices. We encourage you to read their privacy statements before providing any personal data.

10. Changes to This Privacy Policy

Last updated: 18 August 2025

We may update this Privacy Policy from time to time. Minor changes may not be notified, but significant changes will be communicated to you, and where necessary, your consent will be sought.