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Privacy Policy

Last updated: 7 June 2026

This policy is adapted from FundingRock's published privacy policy and aligned to RockPartners. Two areas differ materially from FundingRock's own operation and are marked [REVIEW] below — the Meta Pixel and affiliate-applicant data. Have FundingRock's compliance contact confirm those before going live.

Purpose

Your privacy is very important to us. This Policy describes how RockPartners — an independent affiliate operation that recruits partners to promote FundingRock — collects, processes, and retains personal information about you when you visit the RockPartners website or apply to the RockPartners affiliate program. RockPartners is operated as an independent master affiliate [DATA CONTROLLER: currently operated by an individual; to be updated to the operating entity once formed]. RockPartners is not FundingRock; FundingRock is a separate prop trading firm operated by Mindwave (a Cypriot limited liability company, Nicosia, Cyprus) which RockPartners promotes. "Personal information" includes any data that identifies you or can be used to identify you.

We process your information based on legitimate business interests, contractual obligations, and legal compliance. This policy sets out your rights under the General Regulation on Personal Data (EU) 679/2016 as amended (the "GDPR").

Our Firm

RockPartners is an independent master affiliate that recruits and supports partners who promote FundingRock. RockPartners is currently operated by an individual [to be updated to the operating entity and registered address once formed]. Affiliate tracking and partner payouts run through FundingRock's affiliate platform (CellXpert). RockPartners is not FundingRock and does not operate FundingRock's evaluation programs.

Contact Information

If you have any queries about this Privacy Policy or your rights, please contact us at: support@fundingrock.com / +357 22 032052. For affiliate-program matters: affiliates@fundingrock.com.

What information we collect

We may collect information from you when you apply to the affiliate program, contact us, or request information from us. Reasons we collect personal information include: to provide our services and carry out requests; to verify your identity; to comply with applicable laws and regulations; to improve our services; to protect the rights, property and safety of our Firm, employees, associates and partners; and for recruitment and affiliate-onboarding purposes.

[REVIEW — affiliate-specific, not in FundingRock's original] When you apply to the RockPartners affiliate program we collect: your name, email address, primary promotional channel (e.g. social handle or website URL), audience size, estimated monthly traffic/sales, and the description you provide of your audience and promotional approach.

Where applicable we may also collect other contact information, company information, and information necessary for the provision of services or required by legislation (including Anti-Money Laundering and Know Your Client regulations).

Automatically Collected Information

When you visit our website we may collect data such as pages viewed, IP address, location data, device identifiers, and browsing activity.

[REVIEW — RockPartners-specific advertising tooling] Subject to your consent, we use the Meta (Facebook) Pixel on this website for advertising measurement and conversion tracking. The Meta Pixel and other non-essential cookies load only if you accept them via our cookie banner. See our Cookie Policy for details.

How we use your data

Automated Decision-Making and Profiling

We may use automated decision-making tools to fulfil our legal obligations and provide services, including for KYC and marketing purposes.

Consequences of Refusal to Provide Personal Information

If you decline to provide required information, we may be unable to offer you certain services or process your application.

Who we share your data with

To perform our contractual, regulatory, business and legal obligations, we may share your data with: government departments and regulatory authorities; auditors and professional advisers; the courts, police and law enforcement; tax authorities and corporate registries; and third-party service providers we engage (including IT providers, and the affiliate-tracking provider CellXpert). [REVIEW] Affiliate application data submitted via our form is processed by Formspree (form handling) and, where you consent, advertising data is shared with Meta. This is a non-exhaustive list which may vary by service.

Transfer of data

To fulfil our obligations we may transfer your data to other jurisdictions, both within the European Union and outside it. Our Firm and the third parties it works with operate under EU standard contractual clauses in relation to the handling of personal information.

Confidentiality & Security

We are committed to keeping your personal information as secure as possible and have put appropriate safeguards and technical measures in place. However, no system can provide absolute security.

Minors

Our services and website are not intended for individuals under the age of 18 (or the age of legal consent in your jurisdiction). We do not knowingly collect personal information from minors. If you believe a minor has shared information with us, please contact us immediately.

Retention

We retain your data only for as long as needed for the purposes described above. In general we hold data for a period of 6 years from the date of last interaction. Data may be held longer to comply with regulatory and indemnity obligations.

Your rights

You have the right of access, rectification, erasure, restriction of processing, data portability, to object to processing, to complain to the relevant Data Protection Authority, and to withdraw consent — subject to other legal and regulatory requirements. To exercise these, contact support@fundingrock.com.

Data privacy requests and complaints

Submit requests or complaints to affiliates@fundingrock.com, marking the subject "Privacy Request" or "Privacy Complaint", and including full details of your request. [A postal contact address will be added once the operating entity is formed.] We aim to acknowledge receipt within 72 hours (3 working days) and to respond within 3 weeks.

If you are not satisfied with our response, you may lodge a complaint with the data protection authority in your jurisdiction.

Changes to this Privacy Policy

We reserve the right to make changes to this Privacy Policy from time to time to reflect legislative and regulatory changes.

Governing Law

[Governing law to be set based on the operating entity's jurisdiction once formed. Until then, RockPartners operates as an independent affiliate and these terms are read alongside FundingRock's own policies for the platform.]