Safe Banking Systems Privacy Shield Policy

Effective August 23, 2016

Safe Banking Systems Software, LLC is a specialist provider of anti-money laundering and compliance solutions to the financial services and other industries. Protecting our client's data is important to the Company. The Company (hereinafter collectively referred to as the "Company," "we," "us" or "our") adheres to the Privacy Shield Framework concerning the transfer of personal data from the European Union ("EU") to the United States of America. Accordingly, we follow the Privacy Shield Framework published by the U.S. Department of Commerce (the "Framework") with respect to all such data. This privacy policy outlines our general policy and practices for implementing the Privacy Policy Framework, including the types of information we gather, how we use it and the notice and choice that affected clients have regarding our use of and their ability to correct that information. Safe Banking Systems uses personal information to perform watch list screening and entity resolution (customer name matching) under specific client agreements with financial and other institutions regulated under the Bank Secrecy Act and the USA PATRIOT Act. This privacy policy applies to our client’s customer personal information received by the Company whether in electronic, paper or verbal format. If you have any questions or concerns regarding this policy, please call us on + 1(631) 547-5400. We will research and attempt to resolve inquiries, complaints and/or disputes regarding use and disclosure of our client’s customer information in accordance with the Privacy Shield Principles.

Safe Banking Systems complies with the U.S.-EU Privacy Shield Framework as set forth by the U.S. Department of Commerce and subject to the investigatory and enforcement powers of the Federal Trade Commission regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Safe Banking Systems has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view Safe Banking Systems certification, please visit https://www.privacyshield.gov

SCOPE OF THIS POLICY

This Privacy Shield Policy applies only to personal information that is processed, maintained or stored on behalf of Safe Banking Systems' clients. "Personal Information" for purposes of this policy means information relating to an identified or identifiable natural person ("data subject"). An "Identifiable Person" is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to the individual's physical, physiological, mental, economic, cultural or social identity that are within the scope of the EU Privacy Shield Framework, recorded in any form and that is received by a participant from the EU. For the purposes of this policy, Safe Banking Systems receives personal information on customers of our clients that include name, address and date of birth. At the present time personal information governed by this Policy does not include human resources information that belongs to Safe Banking Systems.

NOTICE

Any personal information sent to us by our clients is used exclusively for the purposes and services for which we contracted. We do not share, rent or sell that information to any other parties. We do not collect sensitive information (e.g., personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual). Individuals have the right to access their personal data at the institution where their data resides.

CHOICE

Safe Banking Systems offers our client's the opportunity to choose (opt out) whether their customers' personal information is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the client. This is done through contractual agreements with our clients.

ONWARD TRANSFER

Customer information provided to us by our clients as part of our business service to screen their customers to determine if they match against sanctions, politically exposed persons or adverse media is not disclosed, shared, rented or sold to any third parties other than for national security or law enforcement. In cases of onward transfers of Privacy Shield data to third parties, Safe Banking Systems is potentially liable.

DATA SECURITY

Safe Banking Systems takes steps to protect the information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Safe Banking Systems has implemented appropriate physical, electronic and managerial procedures based on ISO 27002 standards to safeguard and secure the information from loss, misuse, unauthorized access or disclosure, alteration or destruction.

DATA INTEGRITY

We take steps to ensure that the client's data we process is reliable for its intended use, accurate, complete, and current to the extent necessary for the purpose for which we use it.

ACCESS

We maintain personal information solely as a processor on behalf of our clients. In such cases, if clients request access to or correction of information, we will coordinate with the client in accordance with the Privacy Shield Principles and Safe Banking Systems data security procedures.

ENFORCEMENT

We use a self-assessment approach to assure compliance with this privacy policy and periodically verify that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the principles. In compliance with the Privacy Shield Principles, Safe Banking Systems commits to resolve complaints about our collection or use of your personal information. Individuals in the European Union with inquiries or complaints regarding our Privacy Shield policy should first contact:

Safe Banking Systems Software, LLC
Attention: Security

114 Old Country Road
Suite 320
Mineola, NY 11501-4400
USA
Ph: +1 631-547-5400
Fx: +1 631-547-5415

Safe Banking Systems has further committed to refer unresolved Privacy Shield complaints to Judicial Arbitration and Mediation Services (JAMS), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you. If claims are not remedied, under certain limited conditions, individuals may invoke binding arbitration as a last resort before the Privacy Shield Panel.

AMENDMENTS

This privacy policy may be amended from time to time consistent with the requirements of the Privacy Shield. Safe Banking Systems also reviews this policy annually as part of the recertification process.