GIOTRADE Investment Solutions LLC (“GIOTRADE” or “the Firm”) is committed to the lawful, transparent, and responsible processing of personal information in full compliance with the Protection of Personal Information Act, No. 4 of 2013 (“POPIA” or “the Act”), as administered by the Information Regulator of South Africa.

As an investment management firm, GIOTRADE recognizes that the responsible handling of client and stakeholder information is fundamental to maintaining trust, ensuring regulatory compliance, and safeguarding client interests.

This Policy applies to all personal information processed by GIOTRADE in the course of:

• Investment management mandates and portfolio administration
• Client onboarding, identity verification, and due diligence
• Portfolio monitoring, performance reporting, and client communications
• Internal risk management, compliance, and operational processes
• Interactions with third-party service providers, regulators, and counterparties

“Personal Information” means information relating to an identifiable, living, natural person or an identifiable, existing juristic person, including but not limited to:

• Identity and biometric verification information
• Contact details and correspondence records
• Financial data, banking details, and source of funds declarations
• Investment objectives, risk tolerance, and portfolio holdings
• Transactional and account-related records
• Employment, income, and economic profile information

“Processing” means any operation or activity, automated or not, concerning personal information, including collection, receipt, recording, organization, storage, updating, distribution, or destruction.

“Responsible Party” means GIOTRADE Investment Solutions LLC, which determines the purpose and means of processing personal information.

GIOTRADE processes personal information strictly within the lawful bases prescribed under POPIA, including:

• Contractual necessity: for the execution and administration of investment mandates
• Legal and regulatory: obligations compliance, reporting, and record-keeping requirements
• Legitimate interests: risk management, fraud prevention, and operational efficiency
• Consent of the data subject: where required and where no other lawful basis applies

In accordance with the Financial Intelligence Centre Act, No. 38 of 2001 (“FICA”), GIOTRADE implements rigorous Know Your Client (KYC) and Anti-Money Laundering (AML) procedures as part of its client onboarding and ongoing due diligence obligations.

In accordance with POPIA, data subjects have the following rights:

• The right to access personal information held by GIOTRADE
• The right to request correction or deletion of inaccurate, irrelevant, or outdated information
• The right to object to the processing of personal information
• The right to withdraw consent where processing is based on consent
• The right to lodge a complaint with the Information Regulator of South Africa

Welcome to GIOTRADE Investment Solutions LLC (“GIOTRADE”, “Company”, “we”, “our”, or “us”). By accessing or using this website, you agree to comply with and be bound by the following Terms of Use. If you do not agree with these terms, please do not use this website.

This website is provided for informational, educational, research, media, and business communication purposes related to GIOTRADE Investment Solutions LLC and its associated services, market commentary, educational material, investment research, trading concepts, and media publications.

Nothing on this website constitutes financial advice, investment advice, portfolio management advice, legal advice, or a solicitation to buy or sell any financial instrument.

All content published on this website, including but not limited to articles, market analysis, trading models, educational materials, videos, podcasts, charts, statistical research, social media content, and reports and publications, is intended strictly for educational and informational purposes only.

Users are solely responsible for any financial decisions they make based on information found on this website. Trading and investing involve substantial risk and may result in the loss of capital.

GIOTRADE Investment Solutions LLC does not guarantee profitability, future performance, investment success, or accuracy of market predictions. Past performance does not guarantee future results.

You acknowledge and agree that:

• You use the information on this website at your own risk
• You are fully responsible for your own trading and investment decisions
• GIOTRADE Investment Solutions LLC shall not be held liable for any direct or indirect losses arising from the use of this website or reliance on its content

All content on this website, including logos, branding, educational systems, trading models, research frameworks, written publications, graphics, videos, documents, and proprietary methodologies, are the intellectual property of GIOTRADE Investment Solutions LLC unless otherwise stated.

You may not copy, reproduce, distribute, republish, sell, modify, or exploit any content without prior written consent from GIOTRADE Investment Solutions LLC. Unauthorized use may result in legal action.

Any trading models, concepts, or methodologies shared by GIOTRADE, including liquidity concepts, price delivery models, institutional repricing theories, statistical volatility frameworks, reversal structures, fractal analysis, and market behavior theories, are educational interpretations developed for market analysis purposes and should not be interpreted as guaranteed trading systems.

Markets are dynamic and outcomes may vary significantly.

This website may contain links to third-party websites, brokers, media platforms, software providers, or external services. GIOTRADE Investment Solutions LLC does not control third-party platforms, is not responsible for their content, and does not guarantee their security, reliability, or accuracy. Users access third-party services entirely at their own risk.

By using this website, you agree not to misuse the website, attempt unauthorized access, distribute malicious software, engage in fraudulent activity, infringe intellectual property rights, or use the website for unlawful purposes. We reserve the right to restrict or terminate access to users who violate these terms.

By using this website, you acknowledge that certain technical information such as browser data, cookies, device information, and analytics data may be collected for operational, analytical, and security purposes. Users are responsible for reviewing the website’s Privacy Policy where applicable.

GIOTRADE Investment Solutions LLC reserves the right to modify these Terms of Use, update website content, suspend services, or discontinue portions of the website at any time without prior notice. Continued use of the website after updates constitutes acceptance of the revised terms.

These Terms of Use shall be governed and interpreted in accordance with the laws applicable within the Republic of South Africa, unless otherwise required by applicable international business regulations.