Privacy Policy

Last Updated: June 12^th, 2025.

IMPORTANT – READ CAREFULLY THE FOLLOWING TERMS AND CONDITIONS (“TERMS”) BEFORE USING THE PLATFORM AND SERVICE FROM WWW.DOMINION-CS.COM OR THEIR SUBDOMAINS, OR OUR “DOMINION MOBILE” APPS AVAILABLE IN THE APPLE STORE AND GOOGLE PLAY (THE “PLATFORM”). BY ACCEPTING THIS TERMS, OR BY USING THE PLATFORM, YOU AGREE TO BE LEGALLY BOUND BY THESE TERMS AND THE ACCOMPANYING TERMS OF USE AVAILABLE AT WWW.DOMINION-CS.COM. IF YOU DON’T AGREE WITH THESE TERMS DO NOT REGISTER AND DO NOT USE THE PLATFORM. DO NOT SELECT “I ACCEPT”, CONTINUE WITH YOUR REGISTRATION, OR USE THE PLATFORM UNTIL YOU HAVE CAREFULLY READ, UNDERSTOOD, AND AGREED TO ALL THESE TERMS. IF YOU DO NOT AGREE TO ALL OF THESE TERMS DO NOT CONTINUE WITH YOUR REGISTRATION AND DO NOT USE THE PLATFORM.

FURTHERMORE, YOU HEREBY WAIVE ANY RIGHTS OR REQUIREMENTS UNDER ANY LAWS OR REGULATIONS IN ANY JURISDICTION WHICH REQUIRES AN ORIGINAL (NON-ELECTRONIC) SIGNATURE OR DELIVERY OR RETENTION OF NON-ELECTRONIC RECORDS, TO THE EXTENT PERMITTED UNDER APPLICABLE MANDATORY LAW.

Dominion Capital Strategies Limited Privacy and Data Protection Policy

Thank you for visiting www.dominion-cs.com or any of their subdomains (together with all content on this site) (the “Platform”) operated by Dominion Capital Strategies Limited. (“Dominion”). Your privacy is important to us. To better protect your privacy, we provide this privacy and data protection policy (“Privacy Policy”) explaining our online information practices and the way your information is collected and used on this Platform. This Privacy Policy forms part of the Terms of Use, available at www.dominion-cs.com.

By accepting this Privacy Policy, or by indicating so in writing, or by using our Platform you (“You”) agree to be bound by the terms of this Privacy Policy from such date. If You do not agree to be bound by any term of this Privacy Policy, You may not make use of the Platform or Services.

Introduction

We are committed to respecting Your online privacy and recognize the need to protect and manage any personally identifiable information (“Personal Information”) You share with us.

“Personal Information” means any information that may be used to identify an individual, including, but not limited to, a first and last name, personal profile, financial information, a home or other physical address, an e-mail address or other contact information.

In order to use the Platform You must be either: (i) a Dominion Customer, (ii) permitted to use the Platform by a Dominion Customer, (iii) a financial advisor that has been accepted by Dominion to refer customers to Dominion, (iv) permitted to use the Platform by an authorized financial advisor, (v) Dominion staff, or (vi) a service provider that participates in back-end or development processes, or (vii) a regulator or valid authority. This will require You to provide us with a password that You will use for Your use of the Platform and other specified information.

The Way We Use Personal Information

Personal Information submitted to us, will be used to contact You and to authenticate Your access to Platform services that you are authorized to access.

We may transfer Your Personal Information to Dominion third-party service providers, only to provide You with the Platform services. We require from our third-party providers that such information be processed in compliance with this Privacy Policy and relevant international data protection standards and laws. Dominion will not engage third parties who do not comply with our data privacy requirements.

We do not share, sell or distribute Your Personal Information with unrelated third parties, and we will only disclose Your Personal Information if we have a good faith belief that disclosure of such information is believed by Dominion to be reasonably necessary to i) comply with any applicable law, regulation, legal process or governmental request, ii) enforce our Terms of Use including investigations of potential violations thereof, iii) detect, prevent, or otherwise address fraud, security or technical issues, or iv) protect against harm to the rights, property or safety of Dominion, the Platform, its users, Yourself or the public.

Legal Basis for Processing

We process your personal data under the following lawful bases:

• Performance of a contract (e.g., for account access or services)
• Compliance with legal obligations (e.g., anti-money laundering regulations)
• Legitimate interests (e.g., platform improvements, fraud prevention)
• Consent (e.g., marketing communications or cookies)

Cookies and Other Tracking Technologies

Some of our Platform pages utilize “cookies” and other tracking technologies. A “cookie” is a small text file that may be used, for example, to collect information about Platform activity. Some cookies and other technologies may serve to recall Personal Information previously indicated by a Platform user. Most browsers allow You to control cookies, including whether or not to accept them and how to remove them.

You may set most browsers to notify You if You receive a cookie, or You may choose to block cookies with your browser. Please note that if You choose to erase or block Your cookies, You will need to re-enter certain identifying information to gain access to certain parts of the Platform.

Tracking technologies may record information such as Internet domain and host names; Internet protocol (IP) addresses; browser software and operating Platform types; clickstream patterns; and dates and times that our Platform is accessed. Our use of cookies and other tracking technologies allows us to improve our Platform and your web experience.

We use cookies to improve your experience. You can control cookie settings and find more information in our Cookie Policy.

Access/Accuracy

To the extent that you do provide us with Personal Information, Dominion wishes to maintain accurate Personal Information. You may check your profile and add /delete information or correct any incorrect information.

In the Event of Merger, Sale, or Bankruptcy

In the event that Dominion is acquired by or merged with a third party entity, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from our users as part of such merger, acquisition, sale, or other change of control, but only in accordance with the terms of this Policy.

Commitment

We are committed to protecting your privacy. Protecting your privacy online is an evolving area, and Dominion sites are constantly evolving to meet these demands. If you have any comments or questions regarding our Privacy Policy, please contact us at legal@dominion-cs.com. We will address any issue to the best of our ability as soon as possible.

Security

Providing security for the information, including the personally identifying information you submit via our Platform is a priority for Dominion. We take appropriate security measures to protect against unauthorized access to; or unauthorized alteration, disclosure, or destruction; of your personally identifying information.  We implement technical and organizational measures to protect your data, including:

• Encryption of data in transit and at rest
• Strict access controls based on roles
• Regular penetration testing and vulnerability scans
• Incident response procedures to address data breaches

Data Protection

1. In respect of any data supplied by You, You warrant and will procure that You and/or Your Users will: (a) have all necessary registrations, consents or authorizations necessary under the applicable law to permit Dominion or any Third Party provider to store and process the data in order to comply with Dominion obligations under this Agreement; (b) comply and will continue to comply with any relevant regulation, guidelines and codes of practice related to data protection; and (c) provide Dominion with any necessary corrections to or changes in the data from time to time; (d) inform Dominion when Customer or Users no longer comply with the data protection provisions of this Agreement; (e) ensure that the data provided is correct as far as reasonably possible;
2. That You and/or Your users have previously obtained the necessary consents to allow Dominion to disclose the data to You;
3. Where You and/or Your users supply data to Dominion, Dominion will: (a) ensure that such data is only used for purposes authorized by Customer or permitted under the relevant data protections laws and regulations, or under the Agreement; (b) promptly notify Customer of any request Dominion receives from data subjects for access or rectification of such data or any correspondence with the relevant information commissioners relating to the data; (c) hold any data as a “data processor” and Customer and its’ Users hereby acknowledge and consent to that role.

Anonymized Data & Meta Data

Dominion uses the non-personally identifiable information obtained from the Platform to provide users with an improved service, to better understand usage of our services, and to create reports that we may provide to users, third parties and/or the general public in our discretion. The information gathered is non-personal statistical information (“Anonymized Data”). By agreeing to this Policy You are providing and/or will procure from your Users consent for Dominion to use such information in the manner described herein and in accordance with this Policy and the terms of the relevant Agreements. You warrant that such processing by Dominion is in accordance with Your obligations under the relavant data protection laws and regulations.

Transfer of Data Abroad

Of course, the Internet is made up of a large number of international connections and the various communications will necessarily result in the transfer of information across international boundaries. Any Personal Information collected from or about users in connection with the Platform, or otherwise under these Terms, will be maintained and processed by Dominion or a party acting on its behalf.  When we transfer your personal data outside the European Economic Area (EEA), we ensure appropriate safeguards such as:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Transfers to countries with adequacy decisions from the European Commission
• Binding Corporate Rules (BCRs), where applicable

A copy of these safeguards can be requested by contacting legal@dominion-cs.com. Your and the Dominion Customer’s assent to these Terms and your continued use of the Platform constitutes Your express understanding and agreement that when Personal Information is provided to Dominion, such data will be processed across a variety of jurisdictions.

Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected. This includes legal, accounting, and reporting requirements. When no longer required, data is securely deleted or anonymized.

Your Rights Under GDPR

As a data subject, you have the right to:

• Access your personal data
• Request rectification or erasure
• Restrict or object to processing
• Data portability
• Withdraw consent at any time (where consent is the basis)
• Lodge a complaint with a supervisory authority

You may exercise these rights by contacting our Data Protection Officer.

General Information

For any data protection questions, please contact our Data Protection Officer at dpo@dominion-cs.com