Privacy

Last Updated: May 01, 2021

CitiFX Privacy Notice

We value the trust and confidence you place in us, and earning your trust in how we collect, use, and share information about you is one of our top priorities.

This CitiFX Privacy Notice (this “Notice”) explains how we may collect, share, use, and protect information concerning you (and other individuals whose information you may provide to us) in connection with the CitiFX website and any access to CitiFX services via a computer, mobile device, or other device (or any other sites or services that link to or reference this Notice), including but not limited to: CitiFX.com, CitiFX Pulse, CitiFX Velocity Trading, CitiFX Click, Citi InstantFX, CitiFX Gateway, and CitiFX Click (collectively, the “CitiFX Services”). In this Notice, “we”, “our”, or “Citi” refers to the legal entity or entities in the Institutional Clients Group division of Citigroup Inc. (“Citigroup”) that provide the CitiFX Services.

We advise you to read this Notice in its entirety, including any jurisdiction-specific provisions in the appendix to this Notice, which will apply to users in certain jurisdictions.

As you review this Notice, here are a few important things to keep in mind:

·     Our services, sites, pages, or other materials, or those of other Citigroup businesses, may have additional terms about the privacy or use of your information. Further information about our collection and use of Personal Information may also be included in agreements between us and you or your firm, in our Terms & Conditions, available at https://www.citifx.com/terms-conditions.html, or in our Electronic Access and User Agreement, available at https://www.citivelocity.com/CVSTATIC_PROD/eppublic/license/FXCash/LicenseAgreement.html. Please review all privacy notices or contractual materials that apply to the specific site or service you are using. Clients of Citi Private Bank should review the applicable privacy notice(s) at https://www.privatebank.citibank.com/home/citi-private-bank-privacy-and-security.html.

·     Unless specifically requested by us, please do not provide particularly sensitive information, whether about yourself or anyone else, such as information regarding racial or ethnic origin, political, religious or other similar beliefs, health or sex life, trade union membership, criminal record, or criminal offences committed or alleged to have been committed.

Contents of this Notice

INFORMATION WE COLLECT

USE OF PERSONAL INFORMATION

SHARING OF PERSONAL INFORMATION

YOUR CHOICES REGARDING YOUR PERSONAL INFORMATION

UPDATING YOUR PERSONAL INFORMATION

SECURITY OF PERSONAL INFORMATION

OTHER IMPORTANT INFORMATION

CONTACT US

APPENDIX — Jurisdiction Specific Provisions

I.     INFORMATION WE COLLECT

We collect two types of information: Personal Information and Other Information.

“Personal Information” is any information:

·  that identifies or can be used to identify you;

·  that relates to, describes, is capable of being associated with, or could reasonably be linked (directly or indirectly) with you; or

·  that can be used to authenticate you or provide access to an account.

 “Other Information” is information that does not and cannot reveal an individual's specific identity, such as information that has been de-identified or aggregated.

For at least the past 12 months, we have collected the following categories of Personal Information from the following sources:

Through the CitiFX Services

What we collect: Through the CitiFX Services, you voluntarily provide us with Personal Information that identifies you as an individual or can be used to identify you as an individual, including information such as your name, addresses, phone number, and e-mail.

(If you provide us information about other individuals, you must refer them to this notice and obtain their consent to our collection and use of their Personal Information as described in this Notice.)

Depending upon the CitiFX Services you request, we may collect additional Personal Information such as: account type and status; access credentials, such as a user ID, password, and security questions; the name of your firm, and your department and role at your firm; tax ID (only if required under applicable law); geolocation (only if required under applicable law); a record of your acceptance of our Terms & Conditions, available at https://www.citifx.com/terms-conditions.html, or our Electronic Access and User Agreement, available at https://www.citivelocity.com/CVSTATIC_PROD/eppublic/license/FXCash/LicenseAgreement.html; and information about your rights of access to the CitiFX Services.

We may collect additional information for specific purposes, which will be disclosed or evident at the time of collection.

We may also collect from you: Internet or other electronic network activity information such as usage and traffic data relating to your access to and use of the CitiFX Services, including pages visited and functions used, as well as certain financial, transaction, and market data; information collected through cookies, web beacons and similar technologies; and aggregated information about your visits to and use of the CitiFX Services. While this information may not directly reveal your individual identity, we may associate this usage and Other Information we collect with Personal Information about you.

We may also monitor and record your telephone, email, instant messaging, and other communications with us in connection with the CitiFX Services.

Our business purposes for collecting this information: Providing and administering the CitiFX Services; intake of new customers and new users of the CitiFX Services; providing customer service; improving the CitiFX Services and your experience of the CitiFX Services; performing research and business analytics, and identifying usage trends; engaging in fraud monitoring and prevention; information security; compliance with applicable laws and regulations; protecting our business and our customers against illegal activity; protecting our and our customers’ legal rights; performing audits; verifying requests made pursuant to this Notice; tailoring and sending marketing communications; managing our business effectively; and developing new products and services.

Through your browser or device

What we collect: Certain information is collected from you automatically through your Internet browser(s) or device(s), such as your IP address; geolocation; Media Access Control (MAC) address; computer type (Windows or Mac) or device manufacturer and model; screen resolution; operating system name and version; language; Internet browser type, version, and settings; installed fonts; and time zone.

We may use attributes associated with your device (such as those described above) in order to create a device fingerprint or identifier so that we can recognize your device, along with the time of your visit and any pages visited.

Our business purpose for collecting this information: Providing and administering the CitiFX Services; intake of new customers and new users of the CitiFX Services; providing customer service; improving the CitiFX Services and your experience of the CitiFX Services; performing research and business analytics, and identifying usage trends; engaging in fraud monitoring and prevention; information security; compliance with applicable laws and regulations; protecting our business and our customers against illegal activity; protecting our and our customers’ legal rights; performing audits; verifying requests made pursuant to this Notice; tailoring and sending marketing communications; managing our business effectively; and developing new products and services.

Using unique identifiers such as cookies, pixel tags, device profiling, and similar technologies

What we collect: We may use unique identifiers such as cookies and similar technologies, such as pixel tags and web beacons, to collect device information; browser and browsing information such as time spent on the CitiFX Services, pages visited, language preferences, and other traffic data. These cookies may contain or reflect segment or other interest-based data in a de-identified form including interests across other sites. We may also collect various attributes associated with your device (such as IP address, installed fonts, language and browser settings, and time zone) in order to create a device fingerprint or identifier so that we can recognize your device.

Our business purpose for collecting this information: Providing and administering the CitiFX Services; intake of new customers and new users of the CitiFX Services; providing customer service; improving the CitiFX Services and your experience of the CitiFX Services; performing research and business analytics, and identifying usage trends; engaging in fraud monitoring and prevention; information security; compliance with applicable laws and regulations; protecting our business and our customers against illegal activity; protecting our and our customer’s legal rights; understanding your interests and preferences; tailoring and sending marketing communications; managing our business effectively; and developing new products and services.

Drawing Inferences from Personal Information

What we develop: We may draw inferences from the Personal Information about you and from information about your firm that we have collected.

Our business purpose for drawing these inferences: Using these inferences for our internal business and operational purposes, including to provide customer service and support; develop and improve our products and services; perform research and business analytics; and to tailor marketing communications from us and our affiliates.

From Third Parties

What we collect: We may collect information about you from third-party sources, including, for example, your firm or employer, financial institutions, government sources, and other individuals. This information may include name and contact information, financial information, and information from government records.

Our business purpose for collecting this information: Providing and administering the CitiFX Services; intake of new customers and new users of the CitiFX Services; engaging in fraud monitoring and prevention; compliance with applicable laws and regulations; protecting our business and our customers against illegal activity; protecting our and our customers’ legal rights; performing audits; and managing our business effectively.

II.     USE OF PERSONAL INFORMATION

We may use the Personal Information we collect from and about you to:

·     Provide and administer the CitiFX Services and the functions and services provided via the CitiFX Services, including to facilitate your use and improve your experience of the CitiFX Services;

·     Manage our businesses, including the use of Personal Information in conjunction with service providers who assist in the management and execution of business functions;

·     Manage our relationship with you and your firm;

·     Meet obligations to and cooperate with regulatory agencies, alternative trading systems, clearing and settlement agencies, brokers, and similar entities;

·     Fulfill our obligations under applicable laws and regulations anywhere in the world, including anti-money laundering and anti-terrorist laws and regulations, cooperating with courts and other tribunals, and with national and international regulatory, law enforcement, prosecutorial, and other government authorities;

·     Protect our business and customers from illegal activities, protect our and our customers’ legal rights, and for information security purposes;

·     Perform research and analysis, including to monitor and improve our own businesses, for marketing purposes, and to generate reports or other content based on research and analysis – although these efforts typically involve Other Information that does not identify individuals; and

·     Communicate with you, including to provide you and your firm with updates, security alerts, and support and administrative messages, and also to inform you and your firm about developments with respect to the CitiFX Services or about other products or services of Citigroup or its affiliates – unless you have informed us that you do not wish to receive marketing information by contacting us as described in this Notice or by using the “unsubscribe” link available in any marketing communications we send.

We may also de-identify or aggregate Personal Information in accordance with applicable laws and industry standards, in order to generate Other Information. We may use or disclose Other Information in any lawful manner.

III.     SHARING OF PERSONAL INFORMATION

During at least the past 12 months, we have disclosed or may have disclosed your Personal Information to the following recipients:

·     Our affiliates or other Citigroup divisions or lines of business, which may receive or have access to Personal Information about you if you access, request, or otherwise use other Citigroup services in connection with your use of CitiFX Services, and as permissible under applicable law;

·     Our or our affiliates’ service providers, who may provide services such as website hosting, data analysis, information technology and related infrastructure provision, and customer service, or otherwise assist in the management and execution of business functions;

·     Regulatory agencies, alternative trading systems, clearing and settlement agencies, brokers, and similar entities; and

·     Your firm or its affiliates.

We may use and disclose your Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, which may include laws outside your country of residence; (b) to respond to requests from courts and other tribunals, and national and international regulatory, law enforcement, prosecutorial, and other government authorities, which may include such authorities outside your country of residence; (c) to enforce our legal rights; and (d) to protect our rights, privacy, safety, or property, or that of our affiliates, you, or others.

We may also disclose Personal Information to a third party in connection with a proposed or completed business transaction, including any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or a portion of our businesses or assets, or in connection with any bankruptcy or similar proceedings.

IV.     YOUR CHOICES REGARDING YOUR PERSONAL INFORMATION

You have certain choices and rights with regard to your Personal Information.

A. Your California Privacy Rights

If you are a California resident, you have the right to request and receive certain information about disclosure of your Personal Information to third parties for their direct marketing purposes. Because it is our policy not to share your Personal Information with third parties for third-party direct marketing purposes without your consent, we are exempt from the requirement to respond to such requests.

For information regarding how to exercise your rights as a consumer under the California Consumer Privacy Act (CCPA), please see the Supplemental Provisions for California Residents in the Appendix to this Notice.

B. Your EEA Privacy Rights

If you are located in the EEA or in another jurisdiction subject to European data protection laws, you may have certain rights with respect to the Personal Information that Citigroup holds about you, which may include the right to access or correct (and sometimes, object to or delete) such information.

For information regarding how to exercise your rights under the General Data Protection Regulation (GDPR) or analogous data protection laws, please see the Supplemental Provisions Regarding Individuals in the EEA in the Appendix to this Notice.

C. Cookies and Similar Technologies

Cookies are small data files that are stored on your device by a website you visit. We use cookies to improve your experience of the CitiFX Services (for example by remembering your preferences and access credentials across different pages and functions of the CitiFX Services) and to measure your activities and use of the CitiFX Services.

You can choose whether to accept cookies through your browser settings. For example, most browsers allow you to automatically decline cookies or decline or accept a particular cookie (or cookies) from a particular site when browsing. If you decide not to accept cookies, some features of the CitiFX Services may not work properly because we may not be able to recognize your device and associate you with your Citi account(s). In addition, the content we provide when you use the CitiFX Services may not be as relevant to you or tailored to your interests.

Local shared objects may be stored on your device when using a media player or other software integrated into the CitiFX Services. Local shared objects are similar to cookies in terms of their operation, but they are not managed in your browser in the same way. Restricting acceptance of local shared objects may impede the functionality of some CitiFX Services, including how certain content is presented. Similarly, certain authentication features of our apps may set a persistent token, similar to a cookie, on your mobile device. This token allows that device to be uniquely associated or bound with your account. This token will remain on your device until you un-enroll from those features or delete the app from your device.

D. Do Not Track

Some browsers have a do not track feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser do not track signals.

V.    UPDATING YOUR PERSONAL INFORMATION

It is important to keep your information accurate and up to date. You can review and make changes to your information through your Citi account, or you may contact us about your Personal Information as provided in the “Contact Us” section below, in order to update or make changes to your Personal Information.

VI.    SECURITY OF PERSONAL INFORMATION

The security of your Personal Information is one of our highest priorities. We protect this information by implementing and maintaining reasonable and appropriate physical, electronic, and procedural security measures and safeguards, including as required under applicable law. We train our employees in the proper handling of Personal Information. When we use other companies to provide services for us that include the use of Personal Information, we require them to protect the confidentiality of Personal Information they receive.

No data transmission over the Internet or wireless network or any data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if the security of your account may have been compromised), please immediately contact us as provided in the “Contact Us” section below.

VII.    OTHER IMPORTANT INFORMATION

A. Notice of Changes

We may change this Notice from time to time. The Last Updated legend at the beginning of this Notice indicates the date of the most recent material changes to this Notice. Any changes will become effective when we post the revised Notice on the CitiFX website or other sites referencing this Notice. Please review this Notice periodically and to check the Last Updated legend to determine whether there have been material changes since the last time you reviewed this Notice.

B. Children

The CitiFX Services are not intended for children under 13 years of age. We do not knowingly solicit information from, or market to, children under 13 years of age. If you have reason to believe that we have collected Personal Information from a child, please contact us as provided in the “Contact Us” section below, so that we may take appropriate action.

C. Third-Party Sites and Services

This Notice does not address, and we are not responsible for, the privacy, security, or other practices of any third parties, including any third party operating any site or service linked to from the CitiFX Services. The inclusion of a link within the CitiFX Services to any third-party site or service does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, wireless service providers, Internet service providers, device manufacturers and/or social media platforms may have their own privacy notices that are different from this one for the information they may access through your use of the CitiFX Services. We encourage you to read their privacy notices as the collection, uses and sharing of information by those third parties may be different from Citi’s practices.

We are not responsible for the information collection, usage, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, or any other third-party app provider, social media platform provider, operating system provider, device manufacturer, or wireless service provider, including with respect to any Personal Information you disclose to other organizations through or in connection with the CitiFX Services.

D. Jurisdictional Issues

The CitiFX Services may be operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than those of the United States. Information about you may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the CitiFX Services, you consent to the transfer of information to countries outside of your country of residence, which may have data protection rules that are different from those of your country, including the United States. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Information.

Please note that CitiFX Services may be operated or provided by a legal entity or entities as set forth in an applicable agreement between us and you or your firm. See, for example, our Electronic Access and User Agreement, available at https://www.citivelocity.com/CVSTATIC_PROD/eppublic/license/FXCash/LicenseAgreement.html.

VIII.   CONTACT US

If you have any questions about this Notice, please contact us through the webform at https://www.citi.com/mss/forms/contact/form.jsp, or using the information available at https://www.citifx.com/contact.html.

If you would like to submit a request pursuant to the California Consumer Privacy Act (CCPA), please visit Citigroup’s Privacy Hub at online.citi.com/dataprivacyhub or call us at (833) 971-1191, or please see section I.B in the Appendix below.

If you would like to submit a request pursuant to the General Data Protection Regulation (GDPR) or analogous data protection laws, please see section II.B in the Appendix below.

 

APPENDIX — Jurisdiction Specific Provisions

Please note that, in addition to the jurisdictional disclosures provided in this Appendix, information about our collection and use of Personal Information specific to your jurisdiction or country of residence may be included in agreements between us and you or your firm, including in our Electronic Access and User Agreement, available at https://www.citivelocity.com/CVSTATIC_PROD/eppublic/license/FXCash/LicenseAgreement.html.

I.     Supplemental Provisions for California Residents

A.     Requests. California residents have certain rights with respect to Personal Information under the California Consumer Privacy Act (CCPA). For purposes of this subsection, the terms “consumer”, “personal information”, “categories of personal information”, “business purpose”, “third party”, and “sale” or “sell” have the meanings ascribed to them in the CCPA. Terms defined under the CCPA may differ in meaning from the common usage of the same terms used elsewhere in this Notice.

1.    You have the right to request, up to two times every 12 months, that Citigroup disclose to you the following: (i) the categories of personal information that Citigroup has collected about you; (ii) the categories of sources from which Citigroup has collected personal information about you; (iii) the business or commercial purpose for collecting or selling your personal information; (iv) the categories of personal information that Citigroup has sold about you in the last 12 months (if any) and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold; (v) the categories of personal information that Citigroup has disclosed about you for our business purposes in the last 12 months and the categories of third parties to whom the personal information was disclosed, by category or categories of personal information for each third party to whom the personal information was disclosed; and (vi) the specific pieces of personal information that Citigroup has collected about you. Please note that personal information that Citigroup has collected in connection with financial products and services provided for primarily personal, family, or household purposes is not subject to the requirements of CCPA because it is already protected under existing federal and California state privacy laws, including the Graham-Leach-Bliley Act (GLBA).

2.    You have the right to receive a copy of your personal information in a portable format.

In response to verified requests pursuant to #1 or #2 above, we will confirm receipt of the request within 10 business days of receipt of the request, and we will disclose and deliver the required information to you free of charge within 45 days of receiving a verifiable consumer request. We may extend this time period to provide once by an additional 45 days when reasonably necessary, in which case we will provide notice of the extension within the first 45-day period.

3.    You have the right to request that Citigroup delete personal information collected from you, subject to certain exceptions under applicable law.

In response to verified requests pursuant to #3 above, we will confirm receipt of the request within 10 business days of receipt of the request. Following verification of your request, we may require you to separately confirm that you want your personal information to be deleted.

4.    You have the right to opt out of the sale of your personal information to third parties by clicking here to visit our Privacy Hub. CCPA defines sale very broadly, covering both monetary and other consideration. Citigroup does not sell personal information for money. However, we share some types of personal information. See our Privacy Hub.

5.    Citigroup will not discriminate against you because you elect to exercise these rights, including by:

·     Denying goods or services to you.

·     Charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.

·     Providing a different level or quality of goods or services to you.

·     Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

None of the foregoing, however, prohibits Citigroup from charging you a different price or rate, or from providing a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to Citigroup by your data.

B.     Submission of Requests. You may exercise these rights by managing this information through Citigroup’s Privacy Hub at online.citi.com/dataprivacyhub or by calling (833) 971-1191. If you wish to submit a request to have your personal information deleted (see section I.A.3 in this Appendix), please call (833) 981-0270. If you wish to submit any type of CCPA request through an authorized agent, please follow the process in Section I.D. below.

C.     Requests from Households. Citigroup cannot take action in response to a request to know or request to delete as it pertains to household-specific pieces of personal information unless all of the all of the following conditions are satisfied

1.     All consumers of the household must jointly request access or deletion through the processes outlined in this Appendix; and

2.     We are able to individually verify (i) all members of the household (see Section I.E below); and (ii) that all individuals making the request are still members of the household.

D.     CCPA Authorized Agent. CCPA permits consumers to designate authorized agents to submit requests on their behalf. Under CCPA, an authorized agent is a natural person or business entity registered with the Secretary of State to conduct business in California that a consumer has authorized to act on their behalf. If you would like to designate an authorized agent to submit a request to know or a request to delete personal information on your behalf, please call us at (833) 981-0270. Please be advised of the following additional information that will be required:

1.    We require a written power of attorney, executed by you, confirming the authority of the authorized agent with respect to your CCPA request(s). After you initiate a request with us by phone at the number above, we will provide you with a form of power of attorney.

2.    Prior to responding to any request made on your behalf by an authorized agent, we may require you to provide written confirmation directly to us that you have provided the authorized agent permission to submit such request(s) on your behalf.

3.    Once verified (see Section I.E below), your authorized agent may create a unique account for you through Citigroup’s Privacy Hub at online.citi.com/dataprivacyhub and manage your requests through that account.

E.     Verification. Whether you submit a request directly on your own behalf, or through an authorized agent, we will take reasonable steps to verify your identity prior to responding to your requests under CCPA. Upon receiving a request pursuant to I.A.1 or I.A.2 above, we will confirm receipt within 10 days and provide you with information about how we will verify and process the request. In order to verify your request, we will require you to provide your social security number, tax ID number or passport number and issuing country, in addition to your first and last name, email address and mailing address.

II.     Supplemental Provisions Regarding Individuals in the EEA

If you are in the European Economic Area or another jurisdiction subject to the General Data Protection Regulation, Regulation (EU) 2016/679 (GDPR) or analogous European data protection laws, including the United Kingdom (collectively referred to here as “EEA”), you have certain rights and protections under the law regarding the processing of your personal data.

For purposes of this subsection, the terms “personal data”, “data subject”, “processing”, and “controller” have the meanings ascribed to them under GDPR. Terms defined under GDPR may differ in meaning from the common usage of the same terms used elsewhere in this Notice.

A.     Legal Basis for Processing. If you are in the EEA, when we process your personal data we will only do so in the following situations:

·     We need to use your personal data to perform our responsibilities under our contract with you (e.g., to facilitate your participation in voluntary polls and surveys).

·     We have a legitimate interest in processing your personal data. For example, we may process your personal data to send you marketing communications, to communicate with you about changes to our services, and to provide, secure, and improve our services.

·     We find such processing is necessary to comply with our legal obligations.

·     We have your consent to do so. When consent is the legal basis for our processing, you may withdraw such consent at any time.

B.     Data Subject Requests. You may have certain rights with respect to the personal data which Citigroup holds about you, including the right to access or correct (and sometimes, object to or delete) the information. If you wish to submit a request to review, correct, update, suppress, restrict or delete personal data that you have provided to us, object to the processing of personal data, or if you would like to receive an electronic copy of your personal data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law) you may contact our GDPR Data Protection Officer by mail at Citigroup Centre, Canada Square, Canary Wharf, London, E14 5LB. We will respond to your request consistent with applicable law.

For your protection, we may only implement requests with respect to the personal data associated with the data subject making the request, or, for example, the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that we may need to retain certain information for recordkeeping purposes or to complete any transactions that you began prior to requesting a change or deletion.

C.     Data Retention. We retain personal data for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

·     The length of time we have an ongoing relationship with you and provide our services to you (for example, for as long as you keep using our services);

·     Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); and

·     Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

D.     Data Controller. Except as otherwise specified on any subsections within sites or apps that comprise Citigroup services, such as the Careers, Alumni, or Citi Consumer Banking subsections, your personal data will be controlled by Citigroup Technology Inc. of 388 Greenwich Street, New York, NY 10013, USA and/or the Citigroup entity which operates the services you are accessing (and/or if you are Citigroup personnel, the Citigroup entity which employs you or contracts with you). A list of certain Citigroup entities can be found at: http://www.sec.gov/Archives/edgar/data/831001/000083100115000043/citi-exhibit2101x12312014.htm. If you would like additional information regarding the applicable Citigroup entity or entities, please contact us.

E.     Data Transfer. Your personal data may be stored and processed in any country where we have facilities or in which we engage service providers. Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en). We will only transfer personal data to non-EEA countries in accordance with applicable legal requirements.

F.     Complaints. You may lodge a complaint with a data protection authority for your country or region where an alleged infringement of applicable data protection law has occurred. A list of data protection authorities is available at https://ec.europa.eu/newsroom/article29/item-detail.cfm.

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