Privacy Shield Framework

This EU-U.S. Privacy Shield Framework (the “Notice”) sets forth the privacy principles followed by Florida International Bankers Association (henceforth referred to as FIBA) in connection with the transfer and protection of “personal information” received from the European Union (“EU”) or Switzerland.

Affirmative Statement

FIBA complies with the U.S.-EU EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Even though FIBA does not have a certification from The U.S. Department of Commerce’s International Trade Administration, due to the low volume of transaction with EU or Switzerland, FIBA represents its adherence to the EU-U.S. Privacy Shield Framework Privacy Policy of notice, choice, onward transfer, security, data integrity, access, and enforcement.

To learn more about the EU-U.S. Privacy Shield Framework program, please visit http://www.export.gov/safeharbor

About the EU-U.S. Privacy Shield Framework

The “EU-U.S. Privacy Shield Framework” program was jointly established in June 2000 by the United States Department of Commerce and the European Commission, as a method for transferring personal information from the EU to companies in the Unites States. Certified companies represent that they are upholding privacy standards for personal information received from the EU that have been jointly accepted by the EU Commission and the US Department of Commerce. These standard exceed current US privacy standards. FIBA is EU-U.S. Privacy Shield Framework certified and upholds this commitment.

“Personal Information” means information that can directly or indirectly lead to the identification of a living person, such as an individual’s name, address, e-mail, telephone number, license number, medical identification number, photograph, or other identifying characteristic. The identification can occur by reference to one or more factors specific to the individual’s physical, physiological, mental, economic, cultural or social identity. Personal information does not include information that has been anonymized, encoded or otherwise stripped of its identifiers, or information that is publicly available, unless combined with other non-public personal information.

Scope

This Notice governs personal information transferred from countries in the EU or Switzerland (which has adopted substantially similar privacy laws to those of the EU), to the United States on behalf of FIBA. It applies to personal information in electronic and off-line formats.

EU-U.S. Privacy Shield Framework Privacy Principles

The following privacy principles apply to the transfer, collection, use or disclosure of personal information form the EU by FIBA.

Notice: FIBA informs individuals in the EU about the purposes for which it collects and uses their personal information, how to contact FIBA, the types of 3rd parties with which FIBA shares their personal information, and the choice and means FIBA offers for limiting the use and disclosure of their personal information.

Consistent with the EU-U.S. Privacy Shield Framework requirements, FIBA may not be in a position to furnish notice in certain limited situation. Specifically, notice is not required where the processing of EU personal information is necessary to respond to a government inquiry; is required by applicable laws, court orders or government regulations; or is necessary to protect FIBA’s legal interests and providing notice would interfere with those interests.

Choice: FIBA will not process personal information about EU individuals for purposes other than those for which the information was originally obtained or subsequently authorized by the EU individual unless the individual affirmatively and explicitly consents (“opt-in”) to the processing, or unless an exception applies. FIBA also provides EU individuals with the opportunity to withdraw consent at any time (“opt-out”), in which case their personal information will not be further processed.

Data Integrity: FIBA seeks to ensure that any personal information held about EU individuals is accurate, complete, current and otherwise reliable in relation to the purposes for which the information was obtained. FIBA collects personal information that is adequate, relevant and not excessive for the purposes for which it is to be processed. EU individuals have a responsibility to assist FIBA in maintaining accurate, complete and current personal information about them.

Transfers to Third Parties: FIBA will not transfer personal information about EU individuals to 3rd parties unless the 3rd party (a) has provided satisfactory assurance to FIBA that it will protect the information consistently with this Notice; or (b) is located in the EU or a country considered “adequate” for privacy by the EU Commission, and therefore is required to comply with the EU data protection laws or substantially equivalent privacy laws; or (c) the 3rd party has also certified to the EU-U.S. Privacy Shield Framework , and is accordingly independently responsible for complying with the EU-U.S. Privacy Shield Framework requirements.

Where FIBA has knowledge that a 3rd party to whom it has provided EU personal information is processing that information in a manner contrary to this Notice or the EU-U.S. Privacy Shield Framework requirements, FIBA will take reasonable steps to prevent or stop the processing.

Access and Correction: Every individual doing business with FIBA has a personal profile in our registration system as to which the individual has full access and control, and is allowed to have access and do corrections at any given time. There are certain limitations to the Access and Correction rights, as set forth in the US Department of Commerce’s EU-U.S. Privacy Shield Framework website. http://www.export.gov/safeharbor

Security: FIBA takes reasonable precautions to protect EU personal information in its possession from loss, misuse, unauthorized access, disclosure, alteration and destruction.

Enforcement: FIBA has established internal mechanisms to verify its ongoing adherence to this Notice. FIBA also encourages individuals covered by this Notice to raise any concerns about our processing of their personal information by contacting FIBA at the address below or by contacting their local privacy officer. FIBA will seek to resolve any concerns. FIBA has also agreed to participate in the dispute resolution program provided by the European Data Protection Authorities.

Limitation on Scope of Principles: Adherence to these privacy principles may be limited to the extent required to meet a legal, governmental, national security or public interest obligation.

Contact Information: Questions or comments about this Notice, please contact us at customerservices@fiba.net