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Data processing addendum
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    Personal Data
Protection Addendum
      March 2025
                                                Personal Data Protection Addendum

This Personal Data Protection Addendum (the “Addendum”) defines the roles of responsibilities of the Parties for their respec-
tive processing of Personal Data and is an integral part of the Business Terms agreed between you and Banking Circle.

This Addendum shall override other terms in the Business Terms and any deviation thereof agreed between you and Banking
Circle if and to the extent there is any conflict or inconsistency and shall survive the termination of the business relationship.

 1.         Definitions                                                  2.   General obligations under Data Protection Law

1.1 In this Addendum the terminology below shall have                    2.1 Each Party acts as separate and independent (but not
    the following meanings:                                                  joint) data controller in respect of the Personal Data
                                                                             processed pursuant to the Services which Banking
                                                                             Circle provides and shall independently determine the
       i.      “Banking Circle” means Banking Circle S.A.;                   purposes and means of such processing.

                                                                         2.2 Each Party acknowledges and confirms that they will
      ii.      “Data Protection Laws” shall have the meaning
                                                                             observe all applicable requirements of Data Protection
               ascribed to such terms in Banking Circle Busi-
                                                                             Laws and these terms in relation to its processing of
               ness Terms.;
                                                                             the Personal Data as independent controller and rep-
                                                                             resents for its own part that all instructions given in
   iii.        “Personal Data” means any personal data (in-
                                                                             respect of the Personal Data shall be in accordance
               cluding any sensitive or special categories of
                                                                             with Data Protection Laws.
               data) that is processed under or in connection
               with the Agreement;
                                                                         2.3 Banking Circle understands that you shall share Per-
                                                                             sonal Data solely for the performance of the Services.
   iv.         “Supervisory Authorities” means any local, na-                Banking Circle does not use or otherwise process any
               tional or multinational agency, department, offi-             such Personal Data, without any lawful ground, nor for
               cial, parliament, public or statutory person or any           any purpose other than facilitating and performing the
               government or professional body, regulatory or                Services. In particular without limitation, Banking Cir-
               supervisory authority, board or other body re-                cle shall not use any such personal data shared by the
               sponsible for administering Data Protection                   Client for marketing, analysis, model building or
               Laws.                                                         providing any other services to the relevant data sub-
                                                                             ject(s) except to evaluate and further develop our
      v.       "EU Standard Contractual Clauses" means ei-                   transaction monitoring tools to provide assurance that
               ther (i) the standard contractual clauses for the             Banking Circle has effective processes to identify,
               transfer of personal data to controllers estab-               manage, monitor and report fraud, money laundering
               lished in third countries which do not ensure an              and terrorism financing risks it is or might be exposed
               adequate level of protection as set out in Com-               to.
               mission Decision 2021/914; or (ii) the standard
               contractual clauses for the transfer of personal          2.4 You acknowledge and understand that Banking Circle
               data to processors established in third countries             processes Personal Data (i) before and in conjunction
               which do not ensure an adequate level of protec-              with the commencement of a business relationship; (ii)
               tion as set out in Commission Decision 2021/914,              throughout the business relationship for the manage-
               in each case as updated, amended, replaced or                 ment of such relationship, including the marketing of
               superseded from time to time by the European                  products or services to you which may be of interest
               Commission;                                                   for you, invoicing, the settlement of disputes and as-
                                                                             sociated business administration; (iii) to enable Bank-
1.2 The terms "data controller", "data subject", "per-                       ing Circle to perform its regulatory and statutory obli-
    sonal data" and "processing” shall have the same                         gations, as part of its Financial Crime Management Ac-
    meanings ascribed to them under Data Protection                          tivity; and (iv) to enable Banking Circle to provide the
    Laws as applicable.                                                      Services, e.g. suppliers incl. in particular IT suppliers
                                                                             or correspondent institutions.
1.3 Capitalised terms not defined in Clause 1 (Definitions)
    shall have the meaning ascribed to them elsewhere
    in the Business Terms.

                                                                                                    Banking Circle      2025.03
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2.5 Each Party shall implement its own measures de-                   Party and provide the other Party with reasonable co-
    signed to ensure performance of and compliance with               operation and assistance in relation to the same.
    its own obligations under Data Protection Laws.
                                                                    5. Requests from Data Subjects
2.6 Each Party shall (without prejudice to the generality of
    the foregoing), be responsible for complying with its
    own security obligations taking into account the state            If a data subject makes a written request to a Party to
    of the art, the costs of implementation and the nature,           exercise their rights in relation to the Personal Data
    scope, context and purposes of the Personal Data pro-             that concerns processing in respect of which another
    cessing, and for implementing its own appropriate                 Party is the controller, that Party shall forward the re-
    technical and organisational measures to protect such             quest to the other Party promptly and in any event
    Personal Data against unauthorised or unlawful loss,              within eight (8) Business Days from the date on which
    alteration, unauthorised disclosure or other unauthor-            it received the request and, upon the other Party’s rea-
    ised or unlawful processing and against accidental or             sonable written request, provide that other Party with
    unlawful destruction or loss.                                     reasonable co-operation and assistance in relation to
                                                                      that request to enable the other to respond to such re-
                                                                      quest and meet applicable timescales set out under
  3. Notice to Data Subject
                                                                      Data Protection Laws.

3.1 You acknowledge that Banking Circle as a data con-              6. Notification of Breach
    troller is obligated to provide the information listed in
    GDPR Article 14 to the relevant data subjects. You will
    assist Banking Circle in ensuring that data subjects              If either Party becomes aware of a Personal Data
    are informed of Banking Circle’s role as Data Control-            breach involving Personal Data that concerns pro-
    ler, in compliance with GDPR article 14.                          cessing in respect of which another Party is the con-
                                                                      troller, it shall notify the other Party without undue de-
3.2 Banking Circle’s privacy notice for data subjects can             lay, and each Party shall co-operate with the other, to
    be found here:                                                    the extent reasonably requested, in relation to any no-
    https://www.bankingcircle.com/privacy-notice                      tifications to the Supervisory Authorities or to data
                                                                      subjects which either Party is required to make under
                                                                      Data Protection Laws.

  4. Complaints
                                                                    7. Third Country Transfers
    If either Party (the "Data Receiving Party") receives
    any complaint, notice or communication from a data                You acknowledge that Banking Circle may transfer
    subject or a supervisory authority which relates di-              and otherwise process or have transferred or other-
    rectly or indirectly to the other Party’s: (i) processing         wise processed Personal Data outside the EEA pro-
    of the Personal Data; or (ii) a potential failure to com-         vided that such transfer is made in compliance with
    ply with Data Protection Laws, the Data Receiving                 applicable Data Protection Laws, including, if applica-
    Party shall, to the extent permitted by law, promptly             ble, EU Standard Contractual Clauses or such other in-
    and in any event within five (5) Business Days forward            ternational transfer mechanism approved under ap-
    the complaint, notice or communication to the other               plicable Data Protection Law.

                                                                                             Banking Circle      2025.03
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