RISKSCREEN CORE TERMS OF USE

These terms govern all use of RiskScreen Core and RiskScreen Pro which occurs after 00.01 UTC on Monday 15th July 2019. These terms govern the use of the RiskScreen Core and RiskScreen Pro customer screening tools, and access to RiskScreen via the RiskScreen API and constitute Your User Agreement with Us.

Definitions

In these terms of use the words and expressions set out below will have the following meanings:

Agreement” means the agreement formed between You and Us by Your acceptance of these Terms

API” means the RiskScreen public Application Program Interface

Assigned User” means a User of RiskScreen who has been granted access to RiskScreen by an Entitled User and who uses RiskScreen by spending valid Search Tokens granted to him or her by an Entitled User from the Entitled User’s stock of valid Search Tokens

Completed Search” means a search request which has been sent to RiskScreen as a result of a User clicking the ‘SEARCH RISKSCREEN’ button and which has returned a valid result. A search becomes a “Completed Search” when RiskScreen delivers the results to the User, not when the User completes a report of their search.

Dow Jones” means Factiva Limited, which is incorporated in England and Wales and whose registered place of business is The News Building, 1 London Bridge Street, London SE1 9GF, United Kingdom, trading as Dow Jones

Dow Jones Information” means information supplied by Dow Jones and distributed to You via the RiskScreen Service. This information includes the records that are searched when You request a RiskScreen search in respect of a search subject’s sanction, PEP, Watch List or Black List status, and any resulting matches that are displayed to You.

Entitled User” means a Registered User of RiskScreen in possession of at least one valid Search Token

Licensors” means the parties which have licensed Us to display and make available to You their intellectual property in the course of the conduct of RiskScreen searches. Our Licensors include, but are not limited to, Dow Jones.

Registered User” means a User who has provided Us with such identity and contact details as We may require

RiskScreen” means the RiskScreen search engine versions 2.4 and above. These terms are expressly intended to cater for both RiskScreen Core and RiskScreen Pro, as well as access to the RiskScreen service via the RiskScreen API. References to “RiskScreen” shall be taken to expressly include reference to RiskScreen Core, RiskScreen Pro, and RiskScreen API unless the context clearly requires otherwise.

RiskScreen API” means the RiskScreen search tool when accessed via the RiskScreen public API

RiskScreen Core” means the RiskScreen search tool when accessed online via GUI

RiskScreen Pro” means the RiskScreen Pro enhanced due diligence search tool (also referred to as ‘RiskScreen EDD’)

RiskScreen Pro Search Token” means an electronic token which can be purchased by Entitled Users and exchanged for Completed Searches on the RiskScreen Pro enhanced due diligence search tool.

Search Token” means an electronic token which can be purchased by Entitled Users and exchanged for Completed Searches on the RiskScreen search engine versions 2.0 and above.

Terms” means the terms of use contained in this document and all of its schedules, to which You must agree prior to accessing or using the RiskScreen Service

The Parties” means You and Us

The RiskScreen Service” means RiskScreen Core and/or RiskScreen Pro and/or RiskScreen API as the context requires. The RiskScreen Service expressly includes the Dow Jones Information

Third Party Content” means any text, files, images, photos, graphics, video, sounds, musical works, or any other materials published or posted on or through Our services produced by third parties (e.g. search results provided by RiskScreen but making use of underlying third party material).

Trial User” means a Registered User of RiskScreen not in possession of at least one valid Search Token

Us, Our, We” means KYC Global Technologies Ltd, trading as RiskScreen, whose registered office is at 95-97 Halkett Place, St Helier, Jersey, JE1 1BX

Users” means Registered Users, Entitled Users, Assigned Users and Trial Users of RiskScreen Core and/or RiskScreen Pro as the context may require

You, Your” means the party which has executed this Agreement by ticking the required box on our website when commencing access to the RiskScreen Service and/or by using the RiskScreen Service after 00.01 UTC on Monday 15th July 2019

Accessing and Using RiskScreen

Modifications

Our Technology

Third Party Content

Dow Jones Information

(a) You have the right to enter into this Agreement and perform Your obligations in the manner contemplated by this Agreement;

(b) that You will comply with all applicable laws and regulations in performing this Agreement; and

(c) this Agreement does not conflict with any other agreement entered into by You.

Reliance on Information and Services

Site Availability

Whilst We will do Our best to ensure that RiskScreen is fully operational at all times, We are not responsible for and shall not be liable to You for any problems or temporary interruptions in using RiskScreen arising from factors outside of Our control (e.g. technical problems from traffic congestion on the internet) or for any problems arising from participating in or from downloading Third Party Content.

Limitation of Our Liability to You

In particular, We will not be liable to You for:

Assignment

Partnership and Agency

The provision by Us of the RiskScreen Service shall not operate to create a partnership between Us, or to authorise You or Us to act as agent for each other.

Third Party Rights

No one other than You or Us, or Our successors and permitted assignees, shall have any right to enforce any of these terms.

Changes to Our terms

We reserve the right to amend these terms of use at any time to ensure that We remain compliant with relevant laws and regulations or for any other purpose whatsoever. By continuing to use Our services after You have been notified of any changes being made, You accept those changes and will be bound by them. Any variations to these terms sought by You must be agreed in writing between Us and You.

Notices

Waiver

No failure or delay by You or Us to exercise any right or remedy provided under this agreement or by law shall constitute a waiver of that or any other right or remedy, nor shall it prevent or restrict the further exercise of that or any other right or remedy. No single or partial exercise of such right or remedy shall prevent or restrict the further exercise of that or any other right or remedy.

Termination

The Effect of Termination

Force Majeure

We shall not in any circumstances have any liability to You if We are prevented from, or delayed in providing the RiskScreen service by omissions or accidents beyond Our reasonable control, including, without limitation, strikes, lock-outs or other industrial disputes, failure of a utility service or transport network, act of God, war, riot, civil commotion, act of terrorism, malicious damage, compliance with any law or governmental order, rule, regulation or direction, accident, breakdown of plant or machinery, fire, flood, storm or default of suppliers or sub-contractors.

The Law that Governs Our Services

These website terms of use and any dispute or claim arising out of or in connection with them (including non-contractual disputes or claims) are governed by and construed in accordance with the laws of the Bailiwick of Jersey and will be subject to the exclusive jurisdiction of the Jersey courts. If any of these terms should be determined to be illegal, invalid or otherwise unenforceable by reason of the laws of any state or country in which these terms are intended to be effective, then to the extent and within the jurisdiction which that term is illegal, invalid or unenforceable, it shall be severed and deleted and the remaining terms of use shall survive, remain in full force and effect and continue to be binding and enforceable.

Agreement to be Bound by these Terms

SCHEDULE 1 – THE RISKSCREEN SERVICE

The following description of what RiskScreen is, and is not, is important. Please read it carefully to ensure that You fully understand the capabilities and limitations of the service which RiskScreen offers.

What RiskScreen is

RiskScreen is an advanced and specialised form of search engine with access to a significant number of open sources, including the general web, certain parts of the deep web, and national sanctions databases. It also maintains access to regularly updated databases of Politically Exposed Persons, national Watch Lists and Black Lists, provided by Dow Jones. The main categories of Politically Exposed Persons maintained on the Dow Jones database utilised by RiskScreen are as follows: A full list of the countries and territories for which Politically Exposed Persons data is maintained can be viewed here /pep-coverage/. Note that the countries and territories for which PEP data is supplied by RiskScreen are liable to change without notice, and that RiskScreen cannot guarantee that all the above categories of PEP will be held for all countries for which PEP data is maintained. To see the lists currently searched, visit the hyperlink/URL above. A full list of the Watch Lists and Black Lists searched by RiskScreen can be viewed here https://search.riskscreen.com/help/watch-list-coverage. Note that the Watch Lists and Black Lists searched by RiskScreen are liable to change without notice. Whilst RiskScreen’s suppliers make all reasonable efforts to maintain PEP, Watch List and Black List data which is current, accurate and comprehensive, RiskScreen makes no warranties or representations regarding the accuracy, currency or completeness of its PEP, Watch List, Black List or Sanctions List data. The onus remains on You at all times to satisfy Yourself as to the accuracy, currency or completeness of any results – including nil returns – which may be produced by searches of RiskScreen. RiskScreen is owned and operated by KYC Global Technologies Limited, trading as RiskScreen.

What RiskScreen is not

RiskScreen has very powerful search capabilities but the information which it searches is limited to that provided by third parties. No research, analysis or other such work is carried out by KYC Global Technologies or its affiliates in connection with the individuals and entities submitted to RiskScreen as search queries. Search results are presented in order of relevance as determined by algorithms utilised by RiskScreen but there is no human intervention in this process. KYC Global Technologies cannot guarantee that, from a User’s perspective, the most relevant results in respect of a search query will be displayed first, or will be visible on the first page of search results. Nor can it guarantee the accuracy, currency or completeness of the content identified in search results drawn from third parties. The onus remains at all times on You as a User to critically interrogate and analyse the results which RiskScreen produces as You would the results of any other search engine.

SCHEDULE 2 – ACCESS, USERS, PAYMENT AND CANCELLATION

Please read the terms in this Schedule carefully as they set out the terms for Your Entitled Usage of RiskScreen. If You access RiskScreen as an Assigned User as a result of being granted access by an Entitled User, these Terms will apply to Your usage as far as they are relevant. The duration of Your access is determined by the Entitled User. Any person over the age of 18 can become an Entitled User but We reserve the right to exclude certain territories from time to time and limit the entitlements on offer in any country. You must be 18 or older and have the power to enter into a contract with Us and not be prevented from doing so under any local laws. Access to RiskScreen Core is by way of a rolling twelve month subscription which, once commenced, automatically renews every twelve months unless cancelled in accordance with the procedure set out under ‘How can I cancel?’ below. Unless You change the volume of searches purchased, You will receive the same Search Bundle every twelve months as that which You first purchased from us. By registering to become an Entitled User, You agree that You have given Us accurate registration details, including payment information and will ensure that We always have up to date contact information. When You become an Entitled User, We will provide You with a username and password to enable You to access RiskScreen. You agree that You will ensure that Your username and password will only be used by You and will be kept secure and confidential. Access to and use of password protected or secure areas of RiskScreen is restricted to authorised Users only. You may not share Your password, account information, or access to RiskScreen, but You may grant access to Assigned Users, provided that You do not levy any charge or receive any reward from Assigned Users or their employers, employees or associates for granting them access to RiskScreen. You are responsible for all activities that occur under Your password or account or as a result of Your having granted Assigned Users access to RiskScreen. You agree to notify Us immediately of any unauthorised use of Your password or account. We reserve the right to refuse any application for access to RiskScreen or to revoke Your access to RiskScreen for any reason and We are under no obligation to divulge that reason to You or any applicant.

What is the duration of my access to RiskScreen?

Entitled User access to RiskScreen is granted to Registered Users who purchase one or more ‘bundles’ of RiskScreen Search Tokens. Your access as an Entitled User will start immediately once You have paid the required set up fee and Your first monthly payment/annual payment in advance, and will continue for as long as You continue to pay the required fee as follows: All unused RiskScreen Search Tokens expire one year after purchase. Purchasing a new bundle of RiskScreen Search Tokens before the expiry of the remaining Search Tokens bought as part of a prior bundle will not extend the life of those other tokens. If at the end of a period lasting one calendar year from the date on which You received a bundle of RiskScreen Search Tokens You still have any unused Search Tokens from that bundle, those tokens will expire, and it will no longer be possible to redeem or exchange them for any RiskScreen searches, nor will they have any residual value whatsoever. For example, if at noon on 1 January 2018 You had purchased a bundle of 1,000 Search Tokens, and at 11.59am on 1 January 2019 You had 25 Search Tokens remaining, those tokens would expire at noon on 1 January 2019 and could not be used for any further searches. Unless You cancel Your subscription in accordance with the ‘How can I cancel?’ section below, it will automatically renew on the anniversary of the date on which Your access first commenced and You will be granted a new bundle of RiskScreen Search Tokens of the same size as that which You first purchased. You can amend the size of the bundle which You would like to receive on renewal by contacting us at least thirty days in advance of Your renewal date.

What does my access to RiskScreen cost?

To become an Entitled User of RiskScreen You must purchase at least one bundle of RiskScreen Search Tokens and pay the required set up fee. If not used, RiskScreen Search Tokens expire one year after purchase. Unexpired RiskScreen Search Tokens may be exchanged for searches conducted on the RiskScreen tool versions 2.4 and above (not including RiskScreen Pro) at a ratio of one Search Token to one Completed Search. Unexpired RiskScreen Search Tokens may be exchanged for searches conducted on the RiskScreen Pro tool at a ratio of ten RiskScreen Search Tokens to one RiskScreen Pro Completed Search. KYC Global Technologies may also sell bundles of RiskScreen Pro Search Tokens. Each RiskScreen Pro Search Token may be exchanged for a RiskScreen Pro search at a ratio of one RiskScreen Pro token to one completed RiskScreen Pro search. RiskScreen Pro Search Tokens cannot be exchanged for RiskScreen Search Tokens or used to pay for searches conducted on the RiskScreen tool versions 2.4 and above. The cost of Your bundle of RiskScreen Search Tokens will be made clear to You on Our sign-up pages and in Your welcome email and may vary from time to time or by country. You agree to pay the fees at the rates notified to You at the time You purchase Your bundle, together with a one off set up fee prior to Your access commencing. We may in Our discretion vary the fees required to purchase a RiskScreen Search bundle from time to time. If the cost of Your next bundle is due to increase by more than 5% since Your last purchase of a bundle of Search Tokens, we will notify You of the same at least 60 days in advance of the renewal of Your annual subscription. Payment can be made using all major credit or debit cards and by direct debit. Where relevant, currency conversion values may fluctuate and conversion fees may be charged by Your bank. By submitting payment details to Us, You promise that You are entitled to purchase access to RiskScreen using those payment details. We reserve the right to change fundamental details of the service which We provide with 30 days’ notice and affected Users may terminate their access to RiskScreen within this notice period.

Can I grant access to other Users?

Entitled Users are permitted to grant access to RiskScreen to as many Assigned Users as they wish, subject to the conditions below. Assigned Users are permitted to conduct searches in RiskScreen provided they first agree to all of the Terms set out in this Agreement. Payment to RiskScreen for the Assigned User’s searches is made by using Search Tokens owned by the Entitled User who granted access to the Assigned User concerned. The cost of performing searches in RiskScreen is the same for an Assigned User as for an Entitled User. Under no circumstances may an Entitled User resell access to RiskScreen to an Assigned User or otherwise charge an Assigned User for granting access to RiskScreen, or profit from that access. Nor may an Assigned User sell access to or the results of RiskScreen searches, or profit from that access. Assigned Users must be bona fide directors, employees, contractors or associates of the same legal entity as employs, contracts with or is directed by the Entitled User. The provision of Assigned User access to RiskScreen to clients or prospective clients of the Entitled User or of the legal entity of which the Entitled User is a director, employee or associate is strictly prohibited.

How can I cancel?

You cancel Your access and the renewal of Your subscription by sending a notice to Us via email addressed to accountmanagement@kyc360.com from Your registered email address on a date which is at least 30 days before Your next annual renewal date. Notifications of Your desire to cancel received by Us after this date will not have effect. When cancelling Your access to RiskScreen, please state the following information in Your email: On receipt of a valid notification from You, We will contact You via email to confirm the cancellation of Your Service, which will have effect from the date when Your next annual renewal was due to take place.

Can I get a refund if I cancel?

If You cancel Your access to RiskScreen within 14 days of the first day on which You received access, and You have not used any Search Tokens, We will refund any payments received from You using the same method of payment that You used to purchase Your bundle of Search Tokens. You will not be entitled to a refund of Your initial payment if You cancel after the first 14 days of the start of Your access to RiskScreen, or if You have used any Search Tokens.

How can We change these Terms?

We may amend these Terms at any time to ensure that We remain compliant with relevant laws and regulations or for any other reason whatsoever. If We make any important changes to these Terms We will notify You by email or by notice on the RiskScreen website.

What happens if I default on a payment?

If You default on any payment, We may: If Your access to RiskScreen has been terminated and You would like to regain access, We have the right to require payment in full of any outstanding amount owed to Us before granting You access.

How do I make a complaint?

If You would like to get in touch with Us to make a complaint, please use one of the following options:

Is there anything else I should know?

We may at any time and at Our sole discretion, terminate Your access to RiskScreen upon reasonable notice, and upon no notice where We believe that We have serious grounds to terminate (for example, for non-payment or breach of these terms). We may screen Your name and address against credit reference and fraud prevention databases when We decide whether or not to accept Your application for access to RiskScreen.  By providing Us with Your details, You confirm that We may carry out these checks. If We do not accept Your application for access to RiskScreen, We will terminate Your access and reimburse any payment that You have made. In addition to these standard access terms, You will also be subject to any specific terms relating to the offers made available to Our Users from time to time. If You are found to be abusing the terms of any of Our offers, We have the right to suspend and/or terminate Your access to RiskScreen and/or offer agreement with Us.

SCHEDULE 3 – PRIVACY AND DATA PROTECTION

Privacy

By becoming an Entitled User of RiskScreen, You agree that We may in Our discretion publicise the fact of Your usage of RiskScreen in marketing or advertising communications made by or on behalf of the KYC Global Technologies, including by use of Your logos, names, trademarks and brand imagery, provided that We do not attribute any endorsement to You other than the bare fact of Your usage of Our services, without Your prior written consent. For other details of how We will process Your personal information, please see Our Privacy Policy, which may be viewed at /riskscreen-privacy-policy/.

Data Protection

This Schedule 3 replaces the Schedule 3 which formed part of the Agreement between You and Us signed on or before 23 May 2018

Definitions

In this Schedule 3 the following terms shall have the following meanings:

clause”: a clause in this Schedule 3.

EEA”: European Economic Area.

EU Data Protection Law”: EU Directive 95/46/EC, as transposed into domestic legislation of each Member State and as amended, replaced or superseded from time to time, including by the GDPR and laws implementing or supplementing the GDPR.

GDPR”: EU General Data Protection Regulation 2016/679.

Third Country”: a country that is not in the European Economic Area.

Your personal data”: all personal data processed by Us or a sub-processor on behalf of You, including special personal data.

1.1 The terms “controller”, “data subject”, “special personal data”, “supervisory authority”, “personal data”, “personal data breach”, “processor” and “processing” shall have the same meaning as in the GDPR.

General

2.1 The Parties will comply with all applicable requirements under EU Data Protection Law. This Schedule 3 is in addition to, and does not relieve, remove or replace, Your or Our obligations under EU Data Protection Law.

2.2 For the purposes of this Schedule 3 We are a data processor within the meaning of the GDPR and You are a data controller within the meaning of the GDPR.

2.3 Under this Schedule 3 the personal data that We agree to process on Your behalf when You access and use Riskscreen for the purposes described in Schedule 1 of this Agreement is the following:

  1. Names of individuals
  2. Countries of association
  3. Dates of birth
  4. Gender
  5. Personal Identification Document Number

2.4 Under this Schedule 3 the personal data that We agree to process on Your behalf when You access and use Riskscreen for the purposes described in Schedule 1 of this Agreement pertains to Your clients and customers (who are, for the avoidance of doubt, the data subjects for the purposes of this Agreement).

2.5 Without prejudice to the generality of clause 2.1 of this Schedule 3, You will ensure that You have all necessary consents and notices in place to enable lawful transfer of personal data to Us for the duration and purposes of this Agreement.

2.6 The Parties may from time to time agree to make such reasonable adjustments to the personal data in clause 2.3 and the categories of data subject in clause 2.4 as they consider necessary to comply with their obligations under Art.28 of the GDPR.

2.7 The duration of Our processing of Your personal data will be for the period necessary for Us to fulfil Our obligations to You under this Agreement.

Processing by Us

3.1 We shall: 3.2 We shall take reasonable steps:

3.3 Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing to be undertaken by Us, as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, We shall in relation to Your personal data implement appropriate technical and organisational measures to ensure a level of security appropriate to that risk, including, as appropriate, the measures referred to in Article 32(1) of the GDPR. In assessing the appropriate level of security, We shall take account in particular of the risks that are presented by the processing, in particular from a personal data breach.

3.4 Taking into account the nature of the processing to be undertaken, We shall assist You by appropriate technical and organisational measures, insofar as this is possible, for the fulfilment of Your obligation to respond to requests for exercising the data subject’s rights under EU Data Protection Law.

3.5 We shall: 3.6 We shall: 3.7 You agree that We may transfer personal data outside of the EEA under the Agreement (hereinafter ‘Permitted Transfers’) where: 3.8 In the case of Us transferring Your personal data under the Agreement to those processors (hereinafter ‘sub-processors’) listed below at clause 4.1, since this will (i) involve the transfer of personal data outside of the EEA and (ii) not to an Adequate Jurisdiction or (iii) not subject to an Approved Contract, You hereby warrant that: 3.8.1 You have obtained the explicit consent of the data subject for such a transfer, as described by clause 3.8, to take place; and 3.8.2 before obtaining the explicit consent of the data subject in accordance with clause 3.8.1, You informed the data subject of the possible risks of such transfers for the data subject due to the absence of an adequacy decision and appropriate safeguards. 3.9 You agree that We can make any necessary consequential amendments to clause 3.8 in order to reflect whether or not a transfer of Your personal data to those sub-processors contained in clause 4.1 will involve (i) the transfer of personal data outside of the EEA and (ii) not to an Adequate Jurisdiction or (iii) not subject to an Approved Contract. 3.10 Where the European Commission has made no adequacy decision pursuant to Art.45(3) of the GDPR in relation to a Third Country, territory or specified sector within that Third Country, or international organisation, You agree that We may also transfer Your personal data where one of the other derogations in Art.49 of the GDPR applies to the transfer.

Sub-Processing

4.1 You agree that We can use the following sub-processors at the date of the Agreement, subject to Us in each case as soon as practicable meeting the obligations set out in clause 4.5. You acknowledge that usage of each of these sub-processors is confined to searches conducted in the RiskScreen Pro tool, where You have expressly requested to search the database of the sub-processor concerned by selecting it as a source for Your Search. We warrant that no data is passed to any of these sub-processors at any time or for any purpose in the course of a RiskScreen Core search or a RiskScreen API search:

Sub-processor Sub-processor Location
Investigative Dashboard Operated by the Organised Crime and Corruption Reporting Project (OCCRP), a registered name of the Journalism Development Network, a charity based in Maryland, USA
OpenCorporates Operated by OpenCorporates Ltd, a UK limited company, but servers hosted globally
Wikileaks Sweden (a country within the EEA) but servers hosted globally
Sub-processor Sub-processor Location
Google LLC Headquartered in the US with servers hosted globally
Bing (Microsoft Corporation) Headquartered in the US with servers hosted globally

4.2 We shall not engage another sub-processor (other than: (i) sub-processors located in the EEA; (ii) sub-processors located in an Adequate Jurisdiction; or (iii) subject to an Approved Contract) to process Your personal data without Your prior written authorisation.

4.3 We shall give You prior written notice of the appointment of any new sub-processor (other than: (i) sub-processors located in the EEA; (ii) sub-processors located in an Adequate Jurisdiction; or (iii) subject to an Approved Contract), including full details of the processing to be undertaken by the sub-processor. If within 14 days of the receipt of that notice You notify Us in writing of any objections (on reasonable grounds) to the proposed appointment, We shall not appoint the proposed sub-processor nor disclose any of Your personal data to the proposed sub-processor.

4.4 With respect to each sub-processor appointed pursuant to this clause 4 (and for the avoidance of doubt excluding: (i) sub-processors located in the EEA; (ii) sub-processors located in an Adequate Jurisdiction; and (iii) subject to an Approved Contract), We shall:

4.5 Where a sub-processor fails to fulfil its data protection obligations under EU Data Protection Law, We shall remain liable to You for the performance of that other processor’s obligations.

Data Subject Rights

5.1 Taking into account the nature of the Processing, We shall assist You by implementing appropriate technical and organisational measures, insofar as this is possible, for the fulfilment of Your obligations, as reasonably understood by Us, to respond to requests to exercise data subject rights under EU Data Protection Law.

5.2 We shall:

Personal Data Breach

6.1 We shall notify You without undue delay upon Us or any sub-processor’s becoming aware of a personal data breach affecting Your personal data, providing You with sufficient information for You to meet any obligations to report or inform data subjects or other supervisory authorities (within the meaning of Art.51 of the GDPR) of the personal data breach under EU Data Protection Law. Such notification shall as a minimum:

6.2 We shall co-operate with You and take such reasonable commercial steps as are directed by You to assist in the investigation, mitigation and remediation of each such personal data breach.

Data Protection Impact Assessments and Prior Consultation

7.1 We shall provide reasonable assistance to You with any data protection impact assessments, and prior consultations with supervisory authorities or other competent data privacy authorities, which You reasonably consider to be required by Arts.35 or 36 of the GDPR or equivalent provisions of any other EU Data Protection Law, in each case solely in relation to processing of Your personal data by, and taking into account the nature of the processing and information available to, Us or a sub-processor.

Deletion or return of Your personal data

Audit rights

where You have identified Your concerns or the relevant requirement or request in Your notice to Us of the audit or inspection.