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Data Transfer and
Outsourcing Addendum
May 2025
Data Transfer and Outsourcing Addendum
This addendum provides information on the various data transfer and/or outsourcing arrangements entered by Banking Circle and
subject to strict confidentiality obligations. It is an integral part of the Business Terms agreed between you and Banking Circle and by
which you have therefore consented to Banking Circle’s data transfer and outsourcing arrangements described herein.
Banking Circle may transfer data and information to employees and other representatives of certain affiliates and/or shareholders in
its group for reporting-, corporate governance-, investor relations-, and similar necessary purposes. In addition, Banking Circle has in
place the data transfer and/or outsourcing arrangements with third parties as set forth below.
Full legal name of Services provided Type of information transmitted to Country where services
the supplier and the supplier are rendered and data
country of stored
establishment
The Sales services consist in Sales and
Commercial activities. Business AML
Banking Circle S.A. (UK consists of 4 main activities: Onboarding, • Client Data
EU
Branch) Transaction Monitoring, AML Change • Client Transactional Data
Management, Sanctions Screening.
Transaction Monitoring, Payments
• Client Data
BC Payments Australia Processing, Client Services, Monitoring of
• KYC data The Netherlands
Pty Ltd Treasury FX Quotation Engine.
• Client Transactional Data
BUREAU VAN DIJK, Information solutions for compliance and
• Client and KYC data Belgium and Germany
Denmark onboarding checks.
Submission of reports to tax authorities • KYC data
Deloitte Solutions Luxembourg
(CRS & FATCA) • Client data
Document signing software for collecting • Client data
Docusign, Inc. EU
signatures. • KYC data
IT Engineering Operations to find the root
cause(s) of operational issues on our
business.
Dynatrace A/S applications that we host ourselves • Client data The Netherlands and Ireland
Monitoring of IT Infrastructure running our
business applications.
Elliptic assists with infrastructure to
optimize due diligence, detection of
account takeovers and fraud, wallet
screening module and ongoing exposure
• Client Data
Elliptic Enterprises assessment for the BC
• KYC data Ireland
Ltd. issued stablecoin. Detect and identify high
• Client Transactional Data
risk transaction and customers across
addresses. Trace source and destination of
funds.
This technology is required to create safe
holding of public and private key pairs. It to • Client Basic Data
Fireblocks Ltd. Israel and EU
allow clients to transact on the blockchain • Client Transactional Data
but also have their virtual assets protected.
This is a software as a service, only the
Gresham
application process is being outsourced. • Client Transactional data Luxembourg and Ireland
Technologies
This is a software as a service, KeepIT
services will be used as a backup of our
• Client Data
KeepIT Office 365 products which are Office 365 Denmark
• Client Transactional data
(e-mail), SharePoint online, Teams and
OneDrive.
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Marketing suppliers • Marketing suppliers may be used to • Client Basic Data USA, Luxembourg, England,
contact you • Personal Data Singapore, Australia, New
York
Cloud infrastructure hosting Banking
Circle’s front-end, e-mail,
• Application front end (BC Connect)
• Anti-money laundering and sanction
screening tools
• Microsoft Office software suite
(email, Word, PowerPoint, Skype and
Microsoft Ireland • Client Basic and KYC data Ireland and the
Teams communications)
Operations, Ltd • Client Transactional data European Union countries
• Customer Relationship Management
system (client due diligence
documentation, financial estimations
of flow and fees)
core banking systems (online banking
application, payments and SWIFT
interface).
Mnemonic Mnemonic will be used as a first line • Client Basic Data Norway
monitoring service of Banking Circle IT
infrastructure to ensure timely response to
identified cyberattacks and vulnerabilities
in our network. In case of suspected data
breaches, security incidents and similar
events that Banking Circle need to react
upon, in order to protect our assets, then
mnemonic will ensure promptly
notifications to the right persons in
Engineering, who can assist on the
investigation.
PwC Luxembourg Submission of payments transactions • Client Transactional Data Luxembourg
reports to tax authorities (CESOP)
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