Dated: May 2019

This is your guide to how personal data is managed by the Clearshift Group which includes Clearshift UAB, Clearshift Israel Ltd, and Clearshift US Company (the “Clearshift Group”). The transfer of data within the Clearshift Group is subject to binding corporate rules which requires all entities within the Clearshift Group to abide by the policies outlined herein. Please read this Privacy Policy carefully. Data privacy is taken very seriously at The Clearshift Group. It is important that you know exactly what we do with the personal information you and others provide to us, why we gather it and what it means to you. This document outlines our approach to Data Privacy to fulfill our obligations under the General Data Protection Regulation (2018).
For the purpose of the relevant data protection regulations, the Clearshift Group is the “data controller” of your information. We are located 309 Fellowship Road, Suite 200, Mt Laurel, NJ 08054. If you have any questions about how we protect or use your data, please email us at privacy@clearshift.eu.
1. How do we protect your personal information
1.1 We are serious about guarding the security of your personal information and use a secure server to store your personal information. All information you provide to us is stored on secure servers.
1.2 As you know, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data during transmission, and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
1.3 We restrict access of your personal information to those employees of the Clearshift Group who have a business reason for knowing such information. We continuously educate and train our employees about the importance of confidentiality and privacy of customer information. We maintain physical, electronic and procedural safeguards that comply with the relevant laws and regulations to protect your personal information from unauthorized access.
2. Information we may collect from you We may collect and use the following data about you: 2.1 Information you give us. (a) You may give us information about you when you sign up to use our service, e.g. when you provide us with your personal details, such as your name and email address. This also includes information you provide through your continued use of our Services via our website or direct communication with our customer support staff. The information you give us may include your name, address, e-mail address, phone number, financial information (including bank account information), payment reason, geographical location, and government identification numbers. (b) We may also need to collect additional commercial and/or identification information from you, e.g. if you send or receive certain high-value or high volume transactions or as needed to comply with our anti-money laundering obligations under applicable law. (c) In providing the personal data of any individual (other than yourself) to us during your use of our Services, you represent that you have obtained consent from such individual to disclose his/her personal data to us, as well his/her consent to our collection, use and disclosure of such personal data, for the purposes set out in this Privacy Policy. 2.2 Information we collect about you. With regard to your use of our Services we may automatically collect the following information: (a) details of the transactions you carry out when using our Services; (b) technical information, including your login information; (c) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website or App (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our Customer Support number. 2.3 Information we receive from other sources. We are working closely with third parties and may receive information about you from them. For example: • the banks you use to transfer money to us will provide us with your basic personal information, such as your name and address, as well as your financial information such as your bank account details; • business partners may provide us with your name and address, as well as financial information, such as card payment information; • advertising networks, analytics providers and search information providers may provide us with pseudonymised information about you, such as confirming how you found our website; • identity and credit reference agencies do not provide us with any personal information about yourself, but may be used to corroborate the information you have provided to us: • Due diligence information obtained from public and/or private sources. 2.4 Information from social media networks. If you log in to our Services using your social media account (for example, Linkedin, Facebook or Google) we will receive relevant information that is necessary to enable our Services and authenticate you. The social media network will provide us with access to certain information that you have provided to them, including your name, profile image and e-mail address. We use such information, together with any other information you directly provide to us when registering or using our Services, to create your account and to communicate with you about the information, products and services that you request from us. 3. Cookies 3.1 Description. Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology For further information, visit allaboutcookies.org. 3.2 There are a number of different types of cookies, however, our website uses: • Functionality – We use these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used. • Advertising – We may use these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. We may share some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website. 3.3 How to Manage Cookies. You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result. 4. Uses made of the information We use your information in the following ways: • (a) to carry out our obligations relating to your contract and/or transactions with us and to provide you with the information, products and services; • (b) to comply with any applicable legal and/or regulatory requirements; • (c) to notify you about changes to our Services; • (d) as part of our efforts to keep our Services safe and secure; • (e) to administer our Services and for internal operations; • (f) to improve our Services and to ensure that they are presented in the most effective manner; • (g) to measure or understand the effectiveness of advertising we serve and to deliver relevant advertising to you; • (k) to combine information we receive from other sources with the information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive); or • (l) to sell our products and services to you; 5. Disclosure of your information 5.1 We may share your information with selected third parties including: • (a) affiliates, business partners, suppliers, our financial service providers and sub-contractors for the performance and execution of any contract and/or transaction we enter into with them or you; • (b) advertisers and advertising networks solely to select and serve relevant adverts to you and others; and • (c) analytics and search engine providers that assist us in the improvement and optimization of our site; and 5.2 We may disclose your personal information to third parties: • (a) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; • (b) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and other applicable agreements; or to protect the rights, property, or safety of the Clearshift Group, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection; • (c) to assist us in conducting or co-operating in investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so; • (d) to prevent and detect fraud or crime; • (e) in response to a subpoena, warrant, court order, or as otherwise required by law; • (f) to assess financial risks; or • (g) to develop customer relationships, services and systems. • (h) under information sharing framework for anti money laundering and law enforcement purposes. 5.3 We do not have a published list of all of the third parties with whom we share your data with, as this would be heavily dependent on your specific use of our Services. To the extent permitted by law, if you would like further information about who we have shared your data with, or to be provided with a list specific to You, you can request this by writing to privacy@clearshift.eu. 6. Where we store your personal data 6.1 The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your payment order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. 7. Sharing your data outside of the EEA 7.1 In order to provide our Services to you, it is sometimes necessary for us to transfer your data to the third parties outlined in section 5.1 that are based outside of the European Economic Area. In these cases, we ensure that both ourselves and our partners take adequate and appropriate technical, physical and organizational security measures to protect your data. We also ensure we have appropriate contractual protections in place with these third parties. 8. Data Retention 8.1 As a regulated financial institution, the Clearshift Group is required by law to store some of your personal and transactional data beyond the closure of your account with us. Your data is only accessed internally on a need to know basis, and it will only be accessed or processed if absolutely necessary. 8.2 Retention periods vary by jurisdiction. You can request information about the retention period in your jurisdiction by writing to us at privacy.clearshift.EU.com 9. Your rights 9.1 You have the right to ask us not to contact you for marketing purposes by contacting us at privacy@clearshift.eu. 9.2 You have the right to correct any personal information we hold on you that is inaccurate, incorrect, or out of date. 9.3 You have the right to ask us to delete your data when it is no longer necessary, or no longer subject to a legal obligation to which the Clearshift Group is subject to. 10. Access to information 10.1 Subject to applicable laws, you may have the right to get a copy of personal data we held about you. Your right of access can be exercised in accordance with the relevant data protection legislation. 12. Changes to our privacy policy 12.1 Any changes we may make to our privacy policy will be posted on this page and, where appropriate, communicated by e-mail. Please check back frequently to see any updates or changes to our privacy policy. 13. Contact 13.1 Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to privacy@Clearshift.eu. 13.2 How to contact appropriate authority. Should you wish to report a complaint or if you feel that the Clearshift Group has not addressed your concern in a satisfactory manner, you may contact the State Data Protection office. State Data Protection Žygimantų str. 11-6a 011042 Vilnius Tel. + 370 5 279 14 45 Fax +370 5 261 94 94 ada@ada.lt http://www.ada.lt/