Privacy Policy
Last Updated: 28 June 2026

1. Introduction

Welcome to iSmarten Member Shares ("Platform"), operated by iSmarten Ltd ("iSmarten", "we", "our", or "us").

This Privacy Policy explains how we collect, use, store, and protect personal information obtained through ismarten.one/shares and related services. We are committed to protecting your privacy and handling personal information in accordance with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Information We Collect

We may collect the following information:

Personal Information

Full name Date of birth Residential address Email address Telephone number Nationality Government-issued identification documents Shareholder account information

Financial and Transaction Information

Share subscription records Payment transaction references Dividend payment records (if applicable)

Technical Information

IP address Browser type and version Device information Website usage information Cookies and similar technologies

3. Purpose of Data Collection

We may use personal information to:

Create and manage shareholder accounts Process applications for iSmarten Member Shares Verify identity and conduct KYC procedures Maintain shareholder records Communicate company announcements and updates Comply with legal and regulatory obligations Prevent fraud and unauthorized activities Improve our services and website functionality

4. Shareholder Verification and KYC

To protect the integrity of the shareholder platform and comply with applicable legal requirements, iSmarten may request identity verification documents and additional information during the application process.

Failure to provide requested information may result in delayed processing, account restrictions, or rejection of an application.

5. Legal Basis for Processing

We process personal information where necessary to:

Perform contractual obligations Comply with legal obligations Protect legitimate business interests Obtain consent where required by law

6. Information Sharing

We do not sell personal information to third parties.

We may share information with:

Payment service providers Identity verification providers Professional advisers Regulatory authorities Government agencies where legally required Technology service providers supporting our operations

All third parties are required to handle information securely and in accordance with applicable laws.

7. Data Security

iSmarten implements reasonable administrative, technical, and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, or destruction.

However, no internet-based system can be guaranteed to be completely secure.

8. Data Retention

Personal information will be retained only for as long as necessary to:

Maintain shareholder records Fulfil legal and regulatory requirements Resolve disputes Enforce company policies

Certain records may be retained for longer periods where required by law.

9. Cookies

Our website may use cookies and similar technologies to improve functionality, security, and user experience.

Users may control cookie preferences through their browser settings.

10. Your Rights

Subject to applicable law, individuals may have the right to:

Access their personal information Request correction of inaccurate information Request deletion of information where appropriate Restrict certain processing activities Object to certain uses of information Request data portability

Requests may be submitted using the contact details provided below.

11. International Transfers

Where information is transferred outside the United Kingdom, iSmarten will take reasonable steps to ensure appropriate safeguards are in place to protect personal information.

12. Third-Party Links

Our website may contain links to third-party websites. iSmarten is not responsible for the privacy practices or content of external websites.

13. Changes to This Policy

iSmarten may update this Privacy Policy from time to time. Updated versions will be published on the website with a revised effective date.

14. Contact Information

For privacy-related enquiries, requests, or concerns, please contact:

iSmarten Ltd

Email: ishares@ismarten.one

Website: ismarten.one/shares

15. Shareholder Information Disclaimer

The iSmarten Member Shares platform is intended to provide shareholder-related information and services. Nothing contained on this website constitutes financial, investment, legal, or tax advice. Prospective applicants should obtain independent professional advice before making decisions relating to share ownership.