1. Introduction

C.FT Ltd, operating under the commercial brand Capital Flow Tech, respects the privacy of website users, prospective clients, professional counterparties, institutional partners and business contacts.

This Privacy Policy explains how CFT collects, uses, stores and protects personal data through this website, contact forms, documentation request forms, Calendly booking links, email communications, onboarding workflows and related business interactions.

Capital Flow Tech provides software infrastructure and API-based algorithmic trading technology for digital-asset markets. CFT does not provide investment advice, portfolio management, asset management, brokerage, custody, deposit-taking or discretionary financial services.

If you have any questions regarding this Privacy Policy, please contact:
partnerships@capitalflowtech.com

2. Changes to This Policy

CFT may update this Privacy Policy from time to time.

Any updated version will be published on this page with a revised “Last updated” date. Where required by applicable law, CFT may provide additional notice of material changes.

You should review this page periodically to remain informed about how CFT processes personal data.

3. Data Controller

For the purposes of applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”) where applicable, the data controller is:

C.FT Ltd

Registration No. 208531 B

PO Box N-9934, 202 Marina Lane

Sandyport, West Bay Street

Nassau, The Bahamas

Email: partnerships@capitalflowtech.com

4. Personal Data We May Collect

CFT may collect personal data that can identify you directly or indirectly, or that is relevant to communication, documentation requests, onboarding, contractual discussions or business relationship management.

This may include:

• Name

• Email address

• Phone number

• Company or organisation

• Role or professional title

• Country or jurisdiction

• Profile type

• Professional or institutional status

• Documentation request details

• Message content submitted through forms

• Calendly booking information

• Email communication history

• Information provided during onboarding or due diligence workflows

• Technical information such as IP address, browser type, device information, website usage data and cookie-related data

Where required for onboarding, contractual review, compliance or due diligence, CFT may request additional information, including identity, corporate, professional, tax, lawful-ownership, source-of-funds, sanctions-screening or other onboarding-related information.

5. How We Collect Personal Data

CFT may collect personal data when you:

• Visit the website

• Submit a contact form

• Request documentation

• Book a call through Calendly

• Contact CFT by email or another communication channel

• Provide information during onboarding, due diligence or contractual discussions

• Interact with website cookies, analytics tools or security tools where applicable

• Are introduced to CFT by a professional contact, partner, platform or institutional counterparty

6. How We Use Personal Data

CFT may use personal data for the following purposes:

• Responding to enquiries

• Reviewing documentation requests

• Assessing profile type and suitability for further discussion

• Managing Calendly bookings and introductory calls

• Providing requested information where appropriate

• Conducting onboarding, due diligence, KYC/KYB or compliance workflows

• Preparing, reviewing or administering contractual documentation

• Managing business communication and relationship records

• Reviewing potential institutional, platform or gateway integrations

• Maintaining website security, functionality and performance

• Protecting CFT’s rights, systems, documents, confidential information and intellectual property

• Complying with applicable legal, regulatory, tax, accounting or operational obligations

CFT will not use personal data for purposes materially different from those described in this Privacy Policy without an appropriate legal basis or, where required, consent.

7. Documentation Requests

Users may request access to selected CFT documentation, including:

• CFT Systematic Macro Swing Module Brief

• CFT Systematic Macro Intraday / Day Module Brief

• CFT Systematic Macro Hybrid Module Brief

• CFT Systematic Gold/XAU Module Brief

• CFT Software Services Pack

• CFT Client Onboarding & Restricted API Setup Guide

• Information relating to Institutional Gateway / SDK Integration

Submitting a documentation request does not guarantee access to documents, create a client relationship or constitute an offer of financial services.

CFT reviews documentation requests manually and may refuse, restrict or delay access at its discretion.

8. Legal Bases For Processing

Where GDPR or similar data protection laws apply, CFT may process personal data on the following legal bases:

• Consent, where information is submitted voluntarily or where consent is required by law

• Contractual necessity, where processing is required to take steps before entering into an agreement or to perform an agreement

• Legal obligation, where processing is required to comply with applicable laws, regulations or lawful requests

• Legitimate interests, including business communication, documentation review, website security, relationship management, due diligence, fraud prevention, protection of CFT’s rights and protection of confidential information

Where CFT relies on legitimate interests, it does so only where those interests are not overridden by applicable individual rights and freedoms.

9. Information fron Third-Party Sources

Where relevant and permitted by applicable law, CFT may obtain information from third-party sources, including:

• Public databases

• Professional profiles

• Corporate registries

• Identity verification providers

• Sanctions-screening tools

• Compliance providers

• Business introduction partners

• Institutional counterparties

• Platform or gateway partners

Such information may be used for onboarding, due diligence, compliance, fraud prevention, relationship review, contractual administration or protection of CFT’s rights and systems.

10. Sharing of Personal Data

CFT may share personal data with selected service providers and professional advisers where necessary,

including:

• Website hosting providers

• Email and communication service providers

• Calendly or scheduling tools

• Cloud storage or document management providers

• Legal, compliance, accounting or professional advisers

• Technology, onboarding or due diligence providers

• Identity verification or sanctions-screening providers

• Institutional counterparties or platform partners where relevant to a requested integration or onboarding process

CFT does not sell personal data.

CFT does not rent, trade or disclose personal data to third parties for their independent marketing purposes.

11. International Transfers

C.FT Ltd is based in The Bahamas and may work with service providers, advisers, counterparties or technology providers in different jurisdictions.

Personal data may therefore be stored, transferred or processed outside the user’s country of residence, including

outside the European Economic Area, the United Kingdom or Switzerland.

Where required by applicable law, CFT will use appropriate safeguards for international transfers of personal data.

12. How We Protect Personal Data

CFT uses reasonable technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration or disclosure.

Such measures may include access controls, secure storage, confidentiality restrictions, operational controls, document access limitations and service provider safeguards.

No method of transmission or storage is fully secure. CFT cannot guarantee absolute security of information transmitted through the internet, email, messaging tools, wireless communication or third-party platforms.

13. Data Retention

CFT retains personal data only for as long as reasonably necessary for the purposes described in this Privacy

Policy, including communication, documentation review, onboarding, contractual, legal, compliance, security and record-keeping purposes.

Retention periods may vary depending on the nature of the relationship, applicable legal requirements, operational needs and potential dispute-resolution requirements.

Where personal data is no longer required, CFT will delete, anonymise or restrict access to such data where appropriate and practicable.

14. Cookies and Analytics

This website may use cookies or similar technologies to support website functionality, security, analytics and performance.

Cookies may be used to:

• Operate the website

• Improve website performance

• Understand website usage

• Support security and fraud prevention

• Remember user preferences where applicable

Where required by applicable law, non-essential cookies will be subject to user consent.

If analytics or tracking tools are used for visitors in the European Economic Area, the United Kingdom or other jurisdictions requiring prior consent, a cookie consent mechanism should be implemented before non-essential cookies are activated.

Users may be able to manage cookies through their browser settings. Disabling cookies may affect website functionality.

15. Marketing and Communications

CFT may use contact details to send administrative, operational or business communications relating to enquiries, documentation requests, onboarding, software infrastructure, website updates or related CFT communications.

Where marketing consent is required by applicable law, CFT will request consent before sending such communications.

Users may request to stop receiving non-essential communications by contacting:

partnerships@capitalflowtech.com

16. Automated Decision-Making

CFT does not knowingly use personal data for automated decision-making producing legal or similarly significant effects.

Documentation requests, onboarding decisions and access to non-public materials are reviewed manually.

17. Your Rights

Depending on your jurisdiction, you may have rights in relation to your personal data, including the right to:

• Access personal data held about you

• Request correction of inaccurate personal data

• Request deletion of personal data

• Object to processing

• Request restriction of processing

• Request data portability

• Withdraw consent where processing is based on consent

• Lodge a complaint with a competent data protection authority

These rights may be subject to legal, contractual, compliance, security, record-keeping or dispute-resolution limitations.

To exercise your rights, please contact:

partnerships@capitalflowtech.com

CFT may take reasonable steps to verify your identity before responding to a rights request.

18. EEA, UK and Swiss Users

Where GDPR, UK GDPR or similar data protection laws apply, CFT acts as data controller for personal data processed through this website, communication channels and onboarding-related workflows.

CFT processes personal data only where an applicable legal basis exists, including consent, contractual necessity, legal obligation or legitimate interests.

Users in the EEA, the United Kingdom or Switzerland may have additional rights under applicable data protection laws, including the right to lodge a complaint with a competent supervisory authority.

19. Third-Party Links and Tools

This website may contain links to third-party websites, tools or platforms, including Calendly or other scheduling, communication, document or technology tools.

CFT is not responsible for the privacy practices, security, availability or content of third-party services.

Users should review the privacy policies of any third-party services they access.

20. No Client Relationship

Submitting personal data through this website, requesting documentation, booking a call or communicating with CFT does not create a client relationship.

Any engagement with CFT remains subject to review, eligibility assessment, contractual documentation and acceptance by CFT.

21. Contact

For any question regarding this Privacy Policy or the processing of personal data, please contact:

partnerships@capitalflowtech.com