Alpha Generation

PRIVACY POLICY & INTERNAL PRIVACY CONTROLS

OVERVIEW

Tattvam Capital Markets (the "Company" or "The Company") places a high priority on the privacy and integrity of the personal information of our customers, both present and future. The Company strives to ensure the safety and confidentiality of all information received from the Customer. This Privacy Policy & Internal Privacy Controls (the "Policy") describes how the Company collects, uses, and protects the personal information of the Customer.

Data Protection Framework

In accordance with the Mauritius Data Protection Act 2017, the Company views the protection, privacy, and safeguarding of the personal and financial information of clients and website visitors as a high priority.

Tattvam Capital Markets (“the Company”) and everyone responsible for using data follow strict rules on how personal information can be collected and used. Users must make sure the information is:

• used fairly and lawfully
• used for limited, specifically stated purposes
• used in a way that is adequate, relevant, and not excessive
• accurate
• kept for no longer than is absolutely necessary
• handled according to people’s data protection rights
• kept safe and secure
• not transferred without adequate protection

Privacy Policy & Internal Privacy Controls

The Company routinely collects personal, confidential, and sensitive non‐public information ("Non-Public Information") from its customers. The Company is committed to safeguarding this information so that its confidentiality can be maintained and unauthorized access, use, or disclosure of this information can be prevented. If the Customer does not want the Company to use the Non-Public Information, the Customer should so inform the Company in writing by sending an email or a letter by registered post at the registered office of the Company. Should the Customer wish to opt out, the Company may not be able to continue providing information, services, and products requested by the Customer and the Company shall have no liability to the Customer in respect of the same.

The Company will not use or disclose Non‐Public Information for any purpose other than for the performance of business activities or if required by law.

All credit/debit card details and personally identifiable information will NOT be stored, sold, shared, rented or leased to any third parties

This Policy describes how Tattvam Capital Markets protects and handles the Non‐Public Information it collects on customers who apply for or receive its products and services. The provisions of this policy apply to current, former, and prospective customers of the Company.

Retention of Records

Tattvam Capital Markets will keep personal data only as long as it is necessary, including for the purposes of updating the product or services or as required by law. When the personal data is no longer required, it will be destroyed either by shredding or other approved destruction methods to prevent unauthorized parties from gaining access to the information during and after the process.

We will safeguard information in our custody

We have developed and will maintain security procedures to safeguard personal data against loss, theft, copying, and unauthorized disclosure, use, or modification. Access to personal data is restricted to employees and authorized service providers who need it to perform their work.

Cookies

What are cookies? Cookies are small pieces of information sent by a web server to store on a web browser so it can be read back later from that web browser. Cookies may be used on some pages of the Site for us to provide Site users with a more customized web browsing experience.

The Protection of Non-Public Information

The Company takes the issue of security very seriously and ensures that all possible measures to ensure the safety of your confidential information, including adhering to strict standards for the internal use of confidential information and using leading data storage technology.

When making a payment with a credit/debit card, the client will be transferred to the site of the processing center where a form has to be filled out. To prevent the unauthorized use of your credit/debit card, the client's card information is transmitted to the Company in a shortened form and through a secure server. In certain exceptional circumstances, the Company may refund payments made by credit or debit card. In this case, the funds will be refunded to the card that was used for the deposit.

The Company may occasionally share Non‐Public Information with its affiliates or third‐party service providers and joint marketers not affiliated with the Company. This information may be shared for a variety of purposes, such as to support the financial products and services provided to customers, to service customer accounts, to cooperate with regulatory authorities and law enforcement agencies, to comply with court orders or other official requests, or, as necessary, to protect the Company’s rights or property.

By accepting the Customer Agreement, the Customer consents to the Company collecting, maintaining, using, and disclosing their Non-Public Information in accordance with the terms of this Policy.

The Company has established procedures designed to prevent the use of insider information by an effective segregation of its activities, including to other members of the Group.

No investment decisions concerning the portfolio of clients shall not be communicated or be (made) available to any unauthorized third party, without the consent of the clients.

Your Consent

By accessing our Site, you consent to Tattvam Capital Markets collecting, maintaining, using, and disclosing your Personal Data in accordance with this privacy policy.

Customer Access to Non-Public Information & Changes to Privacy Policy

The Company endeavors to keep its customer files complete and accurate. It shall also give its customers reasonable access to any Non‐Public Information maintained on that customer

This Policy is set out on the Website, and The Company may update this Policy from time to time. The revised Policy, together with a general notice informing customers of such changes, will be promptly posted to the Website whenever this Policy is materially amended. The Customer irrevocably agrees to the posting of a revised Policy electronically on the Website as constituting actual notice to the Customer. Any dispute over the Policy is subject to this notice. The Customer is encouraged to periodically check back and review this Policy so that the Customer will always know what information the Company collects, how it uses it, and to whom it discloses it.

RISK DISCLOSURE POLICY

Overview

The following statements are intended to inform the Customer of the potential risks involved in trading on financial markets. Customers should be aware of the potential losses associated with such risks. This document forms an integral part of the Agreement between the Company and the Customer. Should there be no clear definition of a term set out in this document, the interpretation of that term shall be governed firstly by the definition given in the Customer Agreement. This document cannot disclose all risks involved in trading due to the wide range of feasible situations.

In issuing a licence to Tattvam Capital Markets (the "Company"), no regulatory authority has vouched for:

• the reliability and financial soundness of the products offered or products on which the Company provides its service; and
• the correctness of statements or opinions expressed by the Company, if any.

Every Customer should deal with the Company at their own risks and shall not be protected by any statutory compensation arrangements in any event whatsoever.

Every person intending to trade on the products offered by the Company is recommended to seek independent advice on the investment viability and risk associated with such products and services proposed by the Company

Risk statements

Online trading involves substantial risks, as indicated hereunder. Prospective Customers should be aware that they can benefit as well as lose all or part of their funds when engaging in trading activities.

In deciding to trade in the Company's products, Customers must rely on their examination of the products, including the merits and risks involved. The Company does not provide advice of any kind, including tax, investment, or legal advice other than general consultations to Customers. The Customer should not risk more than what he is prepared to lose. The Customer must ensure that he understands the risks involved and take into account his level of experience before deciding to trade independent advice and consultation must be sought if the Customer deems it necessary.

Online trading involves a high degree of risk. Customers may not receive the amount that they initially invested due to any of these risks and may lose all or part of their funds.

Effect of leverage

When executing trading operations under margin trading conditions, even small market movements may have a great impact on a Customer’s Trading Account due to the effect of leverage. The Customer must take into consideration that if the trend on the market is against them, the Customer may sustain a total loss of their Initial Margin and any additional funds deposited to maintain Open Positions. The Customer shall be held fully responsible for all risks, financial resources used and the chosen trading strategy.

Many instruments are traded within wide ranges of intraday price movements. Consequently, Customers must carefully consider the fact that there is not only a high probability of profit, but also one of loss.

Technical risks

Customers shall assume the risk of financial loss caused by the failure of information, communication, electronic and other systems.

When executing trading operations through the Client Terminal, the Customer shall assume the risk of financial loss, which can be caused by:

• the failure of the Customer's hardware, software, and internet connection;
• the improper operation of the Customer's equipment;
• the wrong settings in the Client Terminal;
• delayed Client Terminal updates; and
• the Customer’s ignorance of the applicable rules described in the user guide for the Client Terminal and in the Help section.

The Customer acknowledges that at the moment of peak load, there may be some difficulties in getting telephone communication with a company representative, especially on the fast market (for example, when key economic indicators are released).

The Customer acknowledges that under abnormal market conditions, the execution time for Customer Instructions may increase.

Trading platform

The Customer acknowledges that only one Request or Instruction is allowed in the queue. Once the Customer has sent a Request or Instruction, any other Request or Instruction sent by the Customer will be ignored. In the “Order” window, the “Order is locked” message will appear

The Customer acknowledges that the only reliable source of quoting information is the server for Customers with live accounts. The quote base in the Customer terminal shall not be considered a reliable source of quoting information given that in the case of a bad connection between the Client Terminal and the server, some of the quotes simply may not reach the Client Terminal.

The Customer acknowledges that when the Customer closes the window to place/modify/delete an Order, as well as the window to open/close a position, the Instruction or Request which has been sent to the server will not be cancelled.

The Customer assumes the risk of executing unplanned Transactions in the event that the Customer sends another Instruction before receiving the result from the Instruction sent previously.

The Customer acknowledges that if an Order has already been executed but the Customer sends an Instruction to modify the level of a pending Order and the levels of Stop Loss and/or Take Profit orders at the same time, the only Instruction that will be executed is the Instruction to modify the Stop Loss and/or Take Profit levels on the position opened on that Order.

Communications

The Customer shall assume the risk of any financial loss caused by the Customer either not receiving a notification from the Company or it being delayed.

The Customer acknowledges that unencrypted information transmitted by email is not protected from unauthorized access. The Customer also agrees that the Company shall have the right to delete messages sent to the Customer through internal mail 5 (Five) days after they have been sent, despite the fact that the Customer may not have received them yet.

The Customer assumes full responsibility for the safekeeping of information received from the Company and shall bear the risk of any financial loss caused by unauthorized access to the Customer’s trading account by any person.

The Customer shall bear all risks of financial loss caused by a Force Majeure Event.

The Customer shall bear all financial and other risks when completing operations (or actions connected with these operations) on financial markets that are statutorily prohibited or restricted by the legislation of the jurisdiction in which the Customer is resident. The Customer must be aware of commissions and other charges before trading. Charges may be expressed in monetary terms, percentage terms or in other unit of measurement and it is therefore the responsibility of the Customer to understand what such charges amount to.

Reimbursement of Investment

In case the company disengages with an investor whose status (e.g., he/she becomes a PEP) or fitness and propriety changes (e.g., there are hits or adverse media reports or sanctions in the investor) during the business relationship, investments made will then be reimbursed. Investments are made via credit card / wire transfers / Virtual Cards. The withdrawals are made on source-to-source basis. For example, if a deposit is made via wire transfer, the funds will be reimbursed by wire transfer itself.

Complaint handling policy

Summary Of Complaints Procedure

Tattvam Capital Markets (herein the ‘Company’) fully adheres to the rules on complaint handling.

In the event that a dispute arises for instance or for whatever reasons, the Client shall have the right to file a complaint with the Company. This document sets out the Company’s complaint procedures. It has been prepared to demonstrate the Company’s aim to treat its customers fairly at all times.

The Company will follow these 4 steps to ensure your complaint is dealt with appropriately:

• We will record the details of your complaint and contact you within 48 hours of receipt of the complaint and confirm to you the person who will be your contact at the Company.
• We will then thoroughly investigate the basis of the complaint using all the information available to us.
• After the investigation is concluded we will correct any errors on the part of the Company.
• We will then let you know the outcome of our investigation.

Information Required

When making a complaint please could you include the following information:

• Your trading account number;
• Your name and surname;
• A description of the problem and affected transaction number (if applicable)
• The date and time that the issue arose

Contact details of where to make your complaint can be found in Section 4.

The Company shall have the right to refuse a client’s complaint regarding non-trading operations in the following cases:

• where the complaint did not meet the requirements of this Policy;
• where the complaint was not made to the Company according to the provided standard form;
• related to complaint on matters non-trading operations - if the client initiates non-trading operations by way of internal account-to-account transfers to other client accounts held with the Company using funds credited to the client’s Account by way of a non-trading operation currently under dispute, or where the client initiates trading operations using funds that were credited to the client’s Account by way of a nontrading operation currently under dispute.

Timescales

We will always try and deal with your complaint as quickly as possible. An initial response will be sent to you within 48 hours of receiving the complaint. Within this email we will provide you with further details on the process we will take to investigate your complaint.

Kindly note that the Company will assist customers and aim to thoroughly investigate and resolve all complaints as quickly as possible. For simple complaints, the Company will deal with the complaint within a period of 5 business days from proper notification of the complaint. It should be noted that in certain specific situations, this period may be extended to more than 5 business days.

We endeavour to resolve all complaints within a 4 week period. If for any reason this will not be possible, we will write to you notifying you of this. At the latest, your complaint will be dealt with within 8 weeks from the date of receipt of the complaint. We are committed to resolving complaints through our Complaints Handling Procedure.

Please write your complaints to the following email address and it will be replied to within 24 hours: complaints@tattvammarkets.com

CLIENT ONBOARDING PROCESS

Introduction

Tattvam Capital Markets (the “Company”) is authorized and regulated by the Financial Services Commission of Mauritius (“FSC”). The Company is committed to complying with its legal and regulatory responsibilities in relation to Anti-Money Laundering & Counter Terrorist Financing (AML/CFT) and has no appetite for non-compliance. The Board of the Company is responsible for ensuring that this Client Onboarding Process is revised and updated from time to time to be in line with any legislative changes in Mauritius in particular the Mauritius AML Legislations.

This Client Onboarding Process is a mandatory requirement for the Company and applies to all end clients which will be onboarded, be they retail or corporate. It articulates a set of minimum standards and requirements that meet and aim to exceed regulatory and legislative obligations and the guidance provided by the FSC.

Client Onboarding Process (Walkthroughs)

Stage 1: Client Acceptance

1. Sourcing of Clients

The Clients are sourced from its target market and are known to the UBO.

Tattvam Capital Markets will NOT deal with or provide any services or products to any of OFAC (Office of Foreign Assets Control) sanctions countries, to the countries which are of non-cooperative jurisdiction or have been subject of FATF Public Statements.

2. Registration of clients

The Onboarding Team / Backoffice team liaise with prospective clients. All clients are requested to complete the Questionnaire in the form of a Client Application Form along with the Client Agreement and to submit the Customer Due Diligence information (“CDD”) as per the policy of the Company. If the Client refuses to provide the information or such information as may be required, when requested, or appears to have intentionally provided misleading information, the Company will not proceed with opening an account for the client.

Stage 2: Client Approval

3. Referring clients to Compliance approval

Upon obtaining the Client Application form, client agreement and KYC/CDD Documents. The Onboarding Team / Backoffice team refers the client to the Compliance department

4. Approval and opening of client trading account

The Compliance Analyst performs screening on each client. Upon successful approval of client by the Compliance Analyst, the Backoffice team refers the client to the dealing team for opening of client trading account in MetaQuotes trading Software.

5. Client trading account credentials

The Onboarding Team / Backoffice team shares the client trading account credentials with the respective clients. Each client has its own ID and password whereby he can access his account for trading. All trades are executed by the client and the client's account is updated automatically.

Stage 3: Client Funding

6. Funding of trading account

All clients fund their trading accounts through bank transfers. SBM Bank (Mauritius) Ltd (SBM) is the primary bank account and client funds are accepted in the client-segregated accounts. All withdrawals are also processed through the client-segregated accounts.

7. Trading and Monitoring of trades

The dealing team manages the entire trading operations and monitors the trade all clients in case of any margin requirements or any specific request, the Onboarding / Backoffice team manages the communications with the clients.