Third Party Index

Snapshot 78715

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2ba0c7b68c5e509d8735355015326bb23d1d0af02716fb46f2f2d38fa42d1fb2

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Scripts and page chrome removed; this is what change detection compares.

  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.

NEXT GEN BANKING.
POWERED BY THE LATEST TECHNOLOGY.                                                                 Banking Circle_2025.05
 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)

NEXT GEN BANKING.
POWERED BY THE LATEST TECHNOLOGY.                                                               Banking Circle_2025.05