Policies

• Performance – Trans World Compliance will use commercially reasonable efforts to update, augment and maintain the content and business rules, as compiled from selected public records and other sources. Subscriber accepts all content and business rules provided by Trans World Compliance on an “AS IS” basis, with no warranty or guarantee as to the accuracy or completeness of the content and business rules.
• Support – Trans World Compliance will offer e-mail support through the Trans World Compliance Web site https://content.transworldcompliance.com/en/contact-us. All support e-mails submitted during regular business hours will be answered within one business day.
• Interruption of Service-
  • Scheduled Interruptions. Subscriber acknowledges that service may be temporarily interrupted or curtailed due to equipment modifications, upgrades, relocations, repairs and other similar activities during the operation and upgrade of service. No reduction of payments will be made in the case of scheduled interruption of service, provided such interruptions do not exceed 48 hours during any consecutive 30-day period.
  • Force Majeure. Trans World Compliance will not be liable for interruption or delays in transmission or errors or defects in transmission or failure to transmit when caused by acts of God, fire, water, riots, war, strikes, acts of Government, third party service providers, or any other causes beyond the control of Trans World Compliance.
  • Internet connectivity. Because Subscriber will access the Service over the public Internet, temporary disruptions of network connectivity will occur from time to time. Internet traffic is usually routed through many different Internet backbone providers on the way to its destination. Trans World Compliance will not be liable for interruption or delays in transmission or errors or defects in transmission or failure to transmit when caused by any Internet backbone provider.
  • Liability. In no event shall Trans World Compliance be liable for any damages due to interruption of Service except a refund of paid subscription fees proportional to downtime.
• Audit- Subscriber understands and agrees that in order to ensure compliance with applicable law; Trans World Compliance reserves the right to conduct periodic reviews of Subscriber’s activity and may, on a random basis, contact Subscriber to provide documentation of executed searches. Trans World Compliance shall also investigate all legitimate reports of abuse or misuse of the Service.
• Notification-
  • Should a data breach occur, all affected subscribers will be notified by Trans World Compliance.
  • Subscriber shall be notified of any legally binding request for disclosure of the Personal Data by a law enforcement authority unless otherwise prohibited, such as a prohibition under law to preserve the confidentiality of law enforcement investigation.

Privacy Shield

Trans World Compliance (“TWC”) is committed to your privacy and supports the EU’s General Data Protection Regulation (GDPR) and the EU-U.S. Data Privacy Framework (DPF).

A. NOTICE & CHOICE

Affirmative Statement of Participation in the EU-US Data Privacy Framework (DPF)

This Statement complies with the Data Privacy Framework as set forth by the U.S. Department of Commerce and GDPR as set forth by the European Union regarding the collection, use, and sharing of personal information. This Privacy and Data Protection Policies statement describes how TWC collects, uses, and transfers data. Please also refer to TWC’s web privacy policies available here.

Jurisdiction

TWC certifies that it adheres to the Data Privacy Framework and GDPR Principles. TWC states that if there is any conflict between the terms of any TWC privacy policy and Data Privacy Framework or GDPR Principles, the Data Privacy Framework and GDPR Principles shall govern.

Scope

TWC’s Privacy and Data Protection Policies applies to its collection, use, and sharing of commercial data (data that TWC processes on behalf of its clients or their partners) and internal data (data that TWC collects for TWC internal purposes such as requests for additional information or to apply for employment with TWC).

TWC’s Data Collection Processes

• Individual and Entity Account Holder information including identifiable information such as name, address, date of birth, and phone numbers
• Tax ID numbers of the aforementioned individuals and entities
• Financial information concerning Accounts held by individuals and entities

TWC End User Data & Privacy Policies

Both TWC and our clients are responsible for end user privacy. TWC provides end user data and privacy policies for our SaaS solutions, as well as a separate policy for the TWC marketing websites.

B. ACCOUNTABILITY FOR ONWARD TRANSFERS

To effectively process data on behalf of our clients to fulfill our client’s compliance obligations, TWC software must share data with certain tax authorities.

C. SECURITY

TWC uses reasonable and appropriate measures to protect personal data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

D. DATA INTEGRITY & PURPOSE LIMITATION

The TWC data pledge expressly disclaims ownership of data in favor of the TWC client.

E. ACCESS

TWC processes data on behalf of its business clients and is not an end user facing company.

F. NOTIFICATION

In the unlikely event of a security breach, within 24 hours of discovery, Trans World Compliance will notify the owners of any affected data.

G. RECOURSE & ENFORCEMENT

For questions or complaints please contact our Data Protection Officer.

H. DISCLOSURES TO LAW ENFORCEMENT

TWC may disclose data in response to lawful requests by public authorities.

Data We Collect From You

Why do we collect Information on the Websites?

We collect any information you voluntarily provide when you visit the Websites to learn more about TWC and its products, the company, investment opportunities, or for other information.

What Information does TWC collect on the Websites?

• The type of browser you used to access the Websites
• The times you accessed the Websites
• The IP address of the device you used to access the Websites
• The pages on the Websites that you viewed
• The pages you visited before navigating to the Websites
• Information about the computer or mobile device you use to access the Websites

How do we Use Information Collected on the Websites?

• Ensuring our Websites remain relevant to your needs
• Delivering TWC newsletters
• Providing confirmations, invoices, technical notices, updates
• Alerting you to new products, special offers, and promotions
• Keeping you informed about TWC promotional events

Third Party Processors

Our carefully selected partners and service providers may process personal information about you on our behalf.