Privacy Policy

This Privacy Policy (“Policy”) is directed at Swiss residents and individuals interacting with any Marex Group entities based in Switzerland, such as Valcourt SA. This Policy explains how we process personal information when:

• You are a customer or a prospective customer of our market-making, brokerage, consultancy, or other services (collectively the “Services”);
• You use our websites/platforms that link back to this Policy, such as marex.com, neon.markets, or valcourt.ch (collectively “Sites”); or
• Otherwise engage with us, such as while working at a counterparty, business partner, or supplier.

Special Note for UK, EEA, or other non-Swiss residents: If you are located in the United Kingdom (UK), European Economic Area (EEA), or other non-Swiss country, please visit marex.com/privacy to view our other privacy policies.

This Policy is provided on behalf of Marex. Marex is a collection of financial services companies ultimately owned by Marex Group plc (collectively the “Marex Group”). Marex Group members include financial services providers with the Marex name and others, such as Valcourt SA (individually and collectively “Marex”).

Valcourt SA
Rue de la Rôtisserie 2
1204 Genève
Switzerland
+41 22 592 53 00
dataprotectionoffice@marex.com

We may collect and process the following categories of personal data depending on the relationship between you and Marex:

• Identity data, such as: full name, national identification number (passport number and tax identification number), date of birth, gender, country of residence, nationality;
• Contact data, such as: name; billing or residential address; email address; and telephone number;
• Professional data, such as: professional background and information relating to professional profile such as directorships;
• Registration and background data, such as: full name; date of birth; gender; country; nationality; professional background; directorships; criminal and offence records; adverse media; politically exposed person (PEP) status); and other know your customer information;
• Financial data, such as: bank account details; payment card details; account holdings; and trade history;
• Transaction data, such as: details about payments made between us and services purchased from us;
• Profile data, such as: account username; password; contact preferences; feedback and survey responses; and the content of any messaging you send using any enquiry form on the Sites;
• Communication data, such as: the content of any messages, emails or calls made between us, including voice recordings of orders placed and confirmations of transactions requested;
• Technical data, such as: your Internet protocol (IP) address, login information, browser type and version, time zone setting and location, ISP and/or mobile carrier, browser plug-in types and versions; browsing activity on our Sites; and file download history;
• Marketing data, such as: marketing and communication preferences; and
• Video, audio and physical access data, such as: CCTV and video recordings and details of your visit to our premises.

We may collect and process personal data about you or relating to you in various ways, including the following:

• if you register to become a customer of the products and services provided by Marex;
• if you are an employee or are otherwise affiliated with an organisation that does business with Marex then that organisation may submit your personal data to us. Similarly, if you are a customer of an introducing broker, the introducing broker may disclose your personal data to us;
• through providing services or working alongside you or your organisation;
• when you communicate with us via telephone, email or otherwise;
• when you are physically within our premises;
• when you attend events hosted or sponsored by us;
• from other Marex Group entities;
• through cookies and other technologies, as you use the Sites. For more specific information about our use of cookies and web technologies, please see our Cookie Policy;
• from third parties, such as exchanges, banks, analytics providers, data brokers, third party directories, business partners, vendors, our corporate customers or other contractual parties;
• from publicly available sources, such as websites, social medial platforms, media reports, and online registers or directories.

If you provide the personal data of another individual to us, (a) you will be responsible for informing the individual that their personal data has been shared with us and that this Privacy Policy will apply, and (b) you represent and warrant that you have obtained the necessary consent(s) from the individual or are otherwise legally entitled or authorised under applicable laws to provide their personal data to us, and for us to collect, use, disclose and process that personal data in accordance with this Privacy Policy.

To serve you better, fulfil our legal obligations, enhance our marketing efforts, and to detect and prevent fraud, we may combine information obtained through various channels.

We collect and process personal data from the following people:

• Clients and Prospective Clients: We collect and process your personal data in connection with providing our Services or to market to you.
• People who work for our clients, prospective clients, and suppliers: If you work for one of Marex’s clients or vendors or otherwise are affiliated with a Marex customer or vendor, we may process your personal data in connection with your organisation’s relationship with Marex.
• Site Users: If you browse our Sites or register an account on our Sites, we will collect and process your personal data in connection with your interaction with the Sites.
• People who contact us with enquiries: If you contact us with an enquiry, submit a complaint, or provide any feedback to us in our surveys and feedback forms, we will collect and process your personal data in connection with your interaction with us.
• Visitors to our offices: If you visit one of our offices, we may process personal data in connection with your visit and any enquiries you make. For example, you may need to provide personal data when signing in as a guest. CCTV footage may also be collected for security purposes.
• Event attendees: If you register/attend one of our events, we will process personal data about you in connection with your attendance, such as registration or dietary information.

Depending on your relationship with us, we collect, use, disclose and process your personal data for various purposes, including to:

• Provide our services to you or your organisation;
• Conduct due diligence and verifying the identity of account holders, beneficial owners, directors and persons authorised to trade;
• Protect our physical premises and digital assets, including by detecting and logging security threats and other malicious activities;
• Monitor and assess compliance with our internal policies and standards;
• Fulfill your or our payment obligations;
• Comply with our legal and regulatory obligations, including detecting and preventing fraud and other market abuse behavior;
• Comply with legal orders and requests, and exercise and defend our rights
• Host and manage events;
• Improve our services and products; and
• Maintain customer relationships and market our products and services.

We may disclose your personal data to various parties, including to parties outside Switzerland, for the purposes set out above. These parties include:

• any entity within the Marex Group;
• the organisation that you represent or is related to you;
• third-party service providers (such as those who provide applications, functionality, data processing, storage, archival, payment or information technology services) and their sub-processors;
• third parties necessary to process transactions and provide products and services to you or your organisation (such as exchanges, banks, counterparties and other relevant parties involved in transactions);
• third parties involved in screening and due diligence checks, such as those that provide database checks relating to anti-money laundering and financial crime;
• courts, law enforcement authorities, regulators or other parties;
• professional advisers (such as our auditors and lawyers);
• event partners and vendors;
• other third parties to establish, exercise or defend legal rights;
• any third party to whom we assign or novate any of our rights or obligations, including a sale of the Marex Group or any of its assets, shares or entities;
• for visitors to our websites, to advertising and marketing partners, please see our Cookie Policy for more information; and
• any other party to whom you authorise us to disclose your personal data, or to whom disclosure is permitted or required by any applicable laws and regulations or court order.

Marex is a global provider of financial services. We may transfer your personal data to Marex Group affiliates and third parties located outside of Switzerland. Destination countries include anywhere Marex has an affiliate. Where we transfer your personal data outside of Switzerland, we will do so in accordance with the Federal Act on Data Protection, including by transferring to countries which are considered to provide an adequate level of data protection as determined by the Federal Council, or in the absence of such a decision, using standard data protection clauses.

We may retain your personal data for as long as the purpose for which the personal data was collected continues, and until it is no longer necessary for any legal or business purposes.

The security of your personal data is important to us. We take appropriate and reasonable security arrangements to keep your personal data, as well as storage media and devices on which personal data is stored, confidential and secure in accordance with our internal procedures, and protected from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.

Subject to applicable legal conditions, you have the right to:

• access and obtain information regarding your personal data;
• rectify your personal data;
• object to the processing of your personal data;
• delete your personal data;
• restrict the processing of your personal data;
• withdraw your consent where Marex obtained your consent to process personal data (this withdrawal will not affect the lawfulness of any processing that took place prior to the withdrawal); and
• data portability.

To exercise your rights, you can contact our Group Data Protection Officer (DPO) by emailing DataProtectionOffice@marex.com.

If you want to exercise your data subject rights as set out in this Policy or have any concerns about the use of your personal data please contact the Marex Group Data Protection Officer (DPO) by emailing DataProtectionOffice@marex.com.

This Policy was last updated in April 2026. We reserve the right to update and change this Policy to reflect any changes to how we process your personal data or changing legal requirements. In case of any such changes, we will post the updated Policy our Sites, at marex.com/privacy, or publish it otherwise. The changes will take effect as soon as they are published.