UNICAPITAL GROUP

PRIVACY POLICY

We are committed to uphold the privacy of Personal Information and process information in compliance with data privacy laws and regulations. Please read this Statement carefully.

The Unicapital Group processes data subject Personal Information, including Sensitive Personal Information and privileged information, as defined under the Data Privacy Act of 2012, perform its obligations, exercise its rights, and pursue its business, operations, and other legitimate interests.

I. Personal Information Processed

The Unicapital Group processes Personal Information, including Sensitive Personal Information and privileged information, regarding a data subject and its Related Parties, including: (i) Information provided by a data subject, or collected from publicly available sources in connection with the provision of the Unicapital Group’s Services; (ii) Identification information (including name, age, date and place of birth, specimen signature, biometric information, and contact information); (iii) Identification information of third parties included in documents that a data subject submit to Unicapital, Inc. (UI), Unicapital Finance and Investments, Inc. (UFII), and Unicapital Securities, Inc. (USI), including constitutional, organizational or incorporation documents, lists of investors, stockholders, directors or officers, business licenses and permits; (iv) Details on a data subject’s profession, job, occupation, business or trade; (v) Financial and credit position, status or background; (vi) Account and financial information (including source of funds); (vii) Information from technologies deployed by Unicapital Group to analyze a data subject’s visits to the Unicapital or UTrade websites or use of UI, UFII or USI’s information technology applications; and (viii) All other Personal Information a data subject submit to UI, UFII or USI as part of the Unicapital Group’s know-your- customer, due diligence, and on-boarding processes.

Please see this Policy’s Definition of Terms for a list of the “Services” of UI, UFII and USI.

II. Purposes and Uses of Processing of Personal Information

The Unicapital Group conducts collection, recording, organization, storage, updating, modification, retrieval, consultation, use, analysis, profiling, consolidation, sharing, transmitting, blocking, erasure, destruction and other similar processing of a data subject or its Related Parties’ Personal Information and Sensitive Personal Information as defined by the Data Privacy Act of 2012 – including but not limited to a data subject’s name, contact details, personal circumstances, TIN, and other information – for the following purposes:

Unicapital, Inc. (UI)

1. (1) To enable or facilitate UI to perform its obligations or enforce its rights with respect to client engagement of UI as lead or participating issue manager, arranger, selling agent, investment banker, underwriter, financial adviser, arranger as well as other foreseeable transactions and arrangements with UI or its related companies;

1. (2) Ensure that client information, status, situation, and activities are in good and acceptable condition for UI to provide or continue providing its services, perform its obligations, enforce its rights, or claim its interests; and

(3) To enable UI to perform its general and usual businesses and services as an investment house. These include acts and decision to clients and prospective clients to (i) profile credit fitness, risks, and tendencies; (ii) making and acting on decisions on client relationships; (iii) transmitting client information to third parties for cross-selling of Unicapital Group products and services, marketing, or collection; (iv) outsourcing or sub-contracting the transmission, storage, or other processing of information; (v) submission of information to regulators and auditors.

Unicapital Finance and Investments, Inc. (UFII)

1. (1) To enable or facilitate UFII to perform its obligations or enforce its rights with respect to client credit line agreement (or other instruments) as well as other foreseeable transactions and arrangements with UFII or its related companies;

1. (2) Ensure that client information, status, situation, and activities are in good and acceptable condition for UFII to provide or continue providing its services, perform its obligations, enforce its rights, or claim its interests; and

(3) To enable UFIII to perform its general and usual businesses and services as a financial company. These include acts and decision to clients and prospective clients to (i) profile credit fitness, risks, and tendencies; (ii) making and acting on decisions on client relationships; (iii) transmitting client information to third parties for cross-selling of Unicapital Group products and services, marketing, or collection; (iv) outsourcing or sub-contracting the transmission, storage, or other processing of information; (v) submission of information to regulators and auditors.

Unicapital Securities, Inc. (USI)

1. (1) To enable or facilitate USI to perform its obligations or enforce its rights with respect to client traditional and online securities brokerage account and instruments such as client Customer

1. (2) Account Information and Agreement Form and Online Trading Services Agreement as well as other foreseeable transactions and arrangements with USI or its related companies;

1. (3) Ensure that client information, status, situation, and activities are in good and acceptable condition for USI to provide or continue providing its services, perform its obligations, enforce its rights, or claim its interests; and

(4) To enable USI to perform its general and usual businesses and services as a securities brokerage firm. These include acts and decision to clients and prospective clients to (i) profile credit fitness, risks, and tendencies; (ii) making and acting on decisions on client relationships; (iii) transmitting client information to third parties for cross-selling of Unicapital Group products and services, marketing, or collection; (iv) outsourcing or sub-contracting the transmission, storage, or other processing of information; (v) submission of information to regulators and auditors.

All Companies of the Unicapital Group

1. (1) Know-your-customer and due diligence processes and identity verification;

1. (2) Investigating identities, backgrounds, and authorities of Related Parties as well as prevention, detection and investigation of crimes, fraud and complaints. Rendering studies and decisions on the opening or continuance of a client, partner, sub-contractor or counterparty account, business, or transaction;

1. (3) Regular and special operations or provision of services, products, facilities, and services to clients and applicant clients, including referring clients and applicant clients to other companies, departments or units of the Unicapital Group for offering or provision of other services;

1. (4) Managing or carrying out any of transactions, requests, or queries in connection with any engagement with any company of the Unicapital Group;

1. (5) Compliance with local, foreign, or international legal and regulatory obligations, including disclosures and reportorial requirements;

1. (6) Implementation of internal credit, risk, control, management, administrative, operational, and compliance functions including conducting internal and external audits;

1. (7) Offering of new or other products and services of the Unicapital Group and other marketing activities;

1. (8) Referral to third parties of acts related touro marketing, advertising, demand and collection;

1. (9) Embodying, enhancing, or upgrading the Unicapital Group’s organizational, infrastructure, operational, technical, and other systems and processes; and

(10) Facilitating any assignee, transferee, participant, or sub-participant in any of Unicapital Group’s rights or obligations.

III. Recipients of Personal Information

In connection with the Purposes, Unicapital Group may transfer and disclose Personal Information relating to a data subject and its Related Parties to the following persons or entities in any jurisdiction in which the Unicapital Group operates (“Recipients”): (i) Unicapital Group, its Related Parties, and their various units, offices, and departments; (ii) Unicapital Group’s agents, contractors, assignees, or third-party service providers; (iii) Any person or entity to whom Unicapital Group is under an obligation or required to make disclosure pursuant to legal process or under the requirements of any law, regulation, court order or agreement (iv) Any disclosure under and for the purposes of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory of industry bodies or associations; (v) Regulators, insurers, trustees, depositories, trade repositories, central clearing parties, clearing houses, affiliated or unaffiliated providers of outsourced or other services; (vi) any court, tribunal, administrative body; (vii) Legal, tax, and other professional advisers and auditors of the Unicapital Group.

IV. Storage and Retention of Personal Information

The Unicapital Group stores Personal Information in its paper-based and electronic storage devices or those of its sub-contractors. Personal Information is retained until ten (10) years from the latter of: (i) the existence of a legal or contractual right or obligation of a Unicapital company to a counterparty, client or employee; (ii) date of last transaction or business relation with a Unicapital company; or (iii) UI, UFII or USI may have use to any part of the information to comply with legal, regulatory or audit requirements or defend its interests against risks and claims.

V. Definition of Terms

Data Subject refers to an individual whose personal, sensitive personal, or privileged information is processed.

Personal Information refers to any information whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual.

Sensitive Personal Information refers to Personal Information:

1. (1) About an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations;

1. (2) About an individual’s health, education, genetic or sexual life of a person, or to any proceeding for any offense committed or alleged to have been committed by such person, the disposal of such proceedings, or the sentence of any court in such proceedings;

1. (3) Issued by government agencies peculiar to an individual which includes, but not limited to, social security numbers, previous or cm-rent health records, licenses or its denials, suspension or revocation, and tax returns; and

(4) Specifically established by an executive order or an act of Congress to be kept classified.

Privileged information refers to any and all forms of data which under the Rules of Court and other pertinent laws constitute privileged communication.

Processing refers to the collecting, recording, organizing, storing, retaining, using, analyzing, copying, transmitting, porting, sharing, exhibiting, deleting, or destroying of Personal Information, including Sensitive Personal Information and privileged information, regarding a data subject or its Related Parties.

Services refer to all acts performed by the companies, departments, officers, employees, and representatives of the Unicapital Group in pursuance with the primary and secondary purposes of each company under their respective Articles of Incorporation as well as the following services offered and provided by the Unicapital Group through various products, channels, or platforms:

Unicapital, Inc.

• Investment Banking services including Strategic and Financial Advisory; Underwriting and Private Placement; Mergers, Acquisitions and Divestitures; Corporate Restructuring; Project Finance; and related services.
• Fixed Income Securities Trading and Distribution services including Government Securities; Corporate Debt Issues; Bank Debt Issues; Other Debt Issues; and related services.

Unicapital Finance and Investments, Inc.

• Retail Loans such as Salary Loans; Personal Loans; Seafarers’ Loan, Teachers’ Loan; and related products.
• Corporate Loans such as Receivables Discounting; Direct Loans; Case-to-case Loans; Credit Line Loans; and related products.

Unicapital Securities, Inc.

• Securities Brokerage including Stock Trading; Margin Facility; Equity Research; Market Seminars; and related services.
• Online Securities Trading including Stock Trading; Margin Facility; Stock Investment Programs; Elite Accounts; Mobile App Trading; and other related services.

Related Parties refer to relatives, colleagues, associates, subsidiaries, affiliates, parent companies, transferees, beneficiaries, joint-venture partners, guarantors, security parties, obligors, directors, trustees, shareholders, partners, investors, beneficial owners, officers, employees, representatives, consultants, account signatories, agents, and subcontractors.

Unicapital Group refers to Unicapital Inc., Unicapital Finance and Investments, Inc., and Unicapital Securities, Inc.

VI. Contact Information

Inquiries and concerns may be addressed to privacy@unicapital-inc.com or by writing to The Data Protection Office, Unicapital Group of Companies, 3/F Majalco Building, Benavidez corner Trasierra Streets, Legaspi Village, Makati City, Philippines 1229.