This WealthPilot Services Privacy Policy (“Services Privacy Policy”) is organized into three sections:

I. The first section (Services Personal Information Data Processing Terms) describes the privacy and security practices that WealthPilot and its affiliates (“WealthPilot”) employ when handling Services Personal Information (as defined below) for the provision of Technical Support, Consulting or other services, including those provided via mobile application, (the “Services”) provided to WealthPilot customers (“You” or “Your”) during the term of Your order for Services. Additional terms may be specified in the relevant privacy and security practices for the Services You have ordered.

Services Personal Information is personal information that is provided by You, resides on WealthPilot, customer or third-party systems and environments, and is processed by WealthPilot on Your behalf in order to perform the Services. Services Personal Information may include, depending on the Services: information concerning family, lifestyle and social circumstances; employment details; financial details; online identifiers such as mobile device IDs and IP addresses, geolocation data, and first party online behavior and interest data. Services Personal Information may relate to Your representatives and end users, such as Your employees, job applicants, contractors, collaborators, partners, suppliers, customers and clients.

II. The second section (System Operations Data Processing Terms) describes the privacy and security practices that apply to personal information that may be incidentally contained in Systems Operation Data that is generated by the interaction of (end-)users of our Services (“Users”) with the WealthPilot systems, tools and networks used to monitor, safeguard and deliver Services to our customer base.

Systems Operations Data may include access, event, diagnostic and other log files, as well as statistical and aggregated information that relates to the use and operation of our Services, and the systems and networks these Services run on.

III. The third section (Communications and Notifications to Customers and Users) applies to both Services Personal Information and personal information contained in Systems Operations Data, describes how WealthPilot handles legally required disclosure requests, and informs You and Users how to communicate with WealthPilot’s Data Protection Officer or file a complaint.

The definitions of Services Personal Information and Systems Operations Data do not include Your or User contact and related information collected from the use of WealthPilot websites, or Your or User interactions with us during the contracting process. WealthPilot’s handling of this information is subject to the terms of the WealthPilot General Privacy Policy.

I. SERVICES PERSONAL INFORMATION DATA PROCESSING TERMS

WealthPilot treats all Services Personal Information in accordance with the terms of Sections I and III of this Policy and Your order for Services.

In the event of any conflict between the terms of this Services Privacy Policy and any privacy terms incorporated into Your order for Services, including an WealthPilot Systems Integration Agreement, the relevant privacy terms of Your order for Services shall take precedence.

1. Purpose of Processing Services Personal Information

WealthPilot may process Services Personal Information for the processing activities necessary to perform the Services, including for creating an WealthPilot services account to access WealthPilot products and services, for testing and applying new product or system versions, patches, updates and upgrades, and resolving bugs and other issues You have reported to WealthPilot.

2. Customer instructions

You are the controller of the Services Personal Information processed by WealthPilot to perform the Services. WealthPilot will process your Services Personal Information as specified in Your Services order and Your documented additional written instructions to the extent necessary for WealthPilot to (i) comply with its processor obligations under applicable data protection law or (ii) assist You to comply with Your controller obligations under applicable data protection law relevant to Your use of the Services. WealthPilot will promptly inform You if, in our reasonable opinion, Your instruction infringes applicable data protection law. You acknowledge and agree that WealthPilot is not responsible for performing legal research and/or for providing legal advice to You. Additional fees may apply.

3. Rights of individuals

You control access to Your Services Personal Information by Your end users, and Your end users should direct any requests related to their Services Personal Information to You. To the extent such access is not available to You, WealthPilot will provide reasonable assistance with requests from individuals to access, delete or erase, restrict, rectify, receive and transmit, block access to or object to processing of Services Personal Information on WealthPilot systems. If WealthPilot directly receives any requests or inquiries from Your end users that have identified You as the controller, we will promptly pass on such requests to You without responding to the end user.

If you are an end user and you have questions about your choices regarding the disclosure and use of Services Personal Information provided to WealthPilot, please consult directly with the organization that collected your information from you.

4. Security and confidentiality

WealthPilot has implemented and will maintain technical and organizational measures designed to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Services Personal Information. These measures, which are generally aligned with the ISO/IEC 27001:2013 standard, govern all areas of security applicable to the Services, including physical access, system access, data access, transmission, input, security oversight, and enforcement.

WealthPilot employees are required to maintain the confidentiality of personal information. Employees’ obligations include written confidentiality agreements, regular training on information protection, and compliance with company policies concerning protection of confidential information.

Additional details regarding the specific security measures that apply to the Services are set out in the security practices for these Services, including regarding data retention and deletion, are available for review.

5. Incident Management and data breach notification.

WealthPilot promptly evaluates and responds to incidents that create suspicion of or indicate unauthorized access to or handling of Services Personal Information.

If WealthPilot becomes aware and determines that an incident involving Services Personal Information qualifies as a breach of security leading to the misappropriation or accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Services Personal Information transmitted, stored or otherwise processed on WealthPilot systems that compromises the security, confidentiality or integrity of such Services Personal Information, WealthPilot will report such breach to You without undue delay.

As information regarding the breach is collected or otherwise reasonably becomes available to WealthPilot and to the extent permitted by law, WealthPilot will provide You with additional relevant information concerning the breach reasonably known or available to WealthPilot.

6. Subprocessors

To the extent WealthPilot engages WealthPilot affiliates and third-party subprocessors to have access to Services Personal Information for the purpose of assisting in the provision of Services, such subprocessors shall be subject to the same level of data protection and security as WealthPilot under the terms of Your order for Services. WealthPilot is responsible for its subprocessors’ compliance with the terms of Your order for Services.

WealthPilot maintains lists of WealthPilot affiliates and subprocessors that may process Services Personal Information.

7. Cross-border data transfers

Services Personal Information may be processed globally as necessary in accordance with this policy and other relevant privacy terms specified applicable to Your Services. If Services Personal Information is transferred to an WealthPilot recipient in a country that does not provide an adequate level of protection for personal information, WealthPilot will take adequate measures designed to protect the Services Personal Information, such as ensuring that such transfers are subject to the terms of a adequate transfer mechanism as required under relevant data protection laws.

8. Audit rights

To the extent provided in your order for Services, You may at Your sole expense audit WealthPilot’s compliance with the terms of this Services Privacy Policy by sending WealthPilot a written request, including a detailed audit plan, at least two weeks in advance of the proposed audit date. You and WealthPilot will work cooperatively to agree on a final audit plan.

The audit shall be conducted no more than once during a twelve-month period, during regular business hours, subject to WealthPilot’s on-site policies and regulations, and may not unreasonably interfere with business activities. If You would like to use a third party to conduct the audit, the third party auditor shall be mutually agreed to by the parties and the third-party auditor must execute a written confidentiality agreement acceptable to WealthPilot. Upon completion of the audit, You will provide WealthPilot with a copy of the audit report, which is classified as confidential information under the terms of Your agreement with WealthPilot.

WealthPilot will contribute to such audits by providing You with the information and assistance reasonably necessary to conduct the audit, including any relevant records of processing activities applicable to the Services. If the requested audit scope is addressed in an audit report issued by a qualified third party auditor within the prior twelve months and WealthPilot provides such report to You confirming there are no known material changes in the controls audited, You agree to accept the findings presented in the third party audit report in lieu of requesting an audit of the same controls covered by the report. Additional audit terms may be included in Your order for Services.

9. Deletion or return of Services Personal Information

Except as otherwise specified in an order for services or required by law, upon termination of services, WealthPilot will return or delete any remaining copies of Your production customer data, including any Services Personal Information, located on WealthPilot systems or Services environments. Additional information on data deletion functionality is provided in the applicable Services descriptions.

II. SYSTEMS OPERATIONS DATA PROCESSING TERMS

1. Responsibility and purposes for processing personal information

WealthPilot and its affiliated entities are responsible for processing personal information that may be incidentally contained in Systems Operations Data in accordance with Sections II and III of this Policy. WealthPilot may collect or generate Systems Operations Data for the following business purposes:

Where relevant, our legal basis for processing Your personal information is as follows:

2. Sharing personal information

Personal information contained in Systems Operations Data may be shared throughout WealthPilot’s organization for WealthPilot’s business purposes. A list of WealthPilot entities is available as indicated above.

We may also share such personal information with the following third parties:

When third parties are given access to personal information contained in Systems Operations Data, we will take the appropriate contractual, technical and organizational measures to ensure, for example, that personal information is only processed to the extent that such processing is necessary, consistent with this Privacy Policy and in accordance with applicable law. WealthPilot does not share or sell Systems Operations Data subject to this Privacy Policy with third parties for any commercial purposes.

3. Cross-border data transfers

If personal information contained in Systems Operations Data is transferred to an WealthPilot recipient in a country that does not provide an adequate level of protection for personal information, WealthPilot will take measures designed to adequately protect information about Users, such as ensuring that such transfers are subject to the terms of an adequate transfer mechanism as required under relevant data protection laws.

4. Security

WealthPilot has implemented appropriate technical, physical and organizational measures in accordance with the WealthPilot security practices designed to protect personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access as well as all other forms of unlawful processing (including, but not limited to, unnecessary collection) or further processing.

5. Individual rights

To the extent personal information about You is contained in Systems Operations Data, You may request to access, correct, update or delete personal information contained in Systems Operations Data in certain cases, or otherwise exercise Your choices with regard to Your personal information by sending us an inquiry. We will respond to your request consistent with applicable law.

If you submit a request, please be specific as to what right you are asserting (e.g., access, correction, etc.) and which specific pieces of personal information are in scope of your request. In some cases, in order to comply with applicable law or a legal obligation, WealthPilot may deny your request or may seek more information from you in order to respond to your request.

III. COMMUNICATIONS AND NOTIFICATIONS TO CUSTOMERS AND USERS

1. Legal requirements.

WealthPilot may be required to provide access to Services Personal Information and to personal information contained in Systems Operations Data as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect Your or a User’s safety or the safety of others, investigate fraud, or respond to government requests, including public and government authorities outside Your or a User’s country of residence, for national security and/or law enforcement purposes.

WealthPilot will promptly inform You of requests to provide access to Services Personal Information, unless otherwise required by law.

2. Data Protection Officer

WealthPilot has appointed a Data Protection Officer who is also WealthPilot’s Chief Privacy Officer. If You or a User believe that personal information has been used in a way that is not consistent with this Privacy Policy, or if You or a User have further questions, comments or suggestions related to WealthPilot’s handling of Services Personal Information or personal information contained in Systems Operations Data, please contact the Data Protection Officer by sending us an inquiry.

3. Filing a complaint

If You or a User have any complaints regarding our compliance with our privacy and security practices, please send us an inquiry. We will investigate and attempt to resolve any complaints and disputes regarding our privacy practices. Users also have the right to file a complaint with a competent data protection authority.

4. Changes to this Services Privacy Policy

This Privacy Policy was last updated on June 7, 2023. However, the Services Privacy Policy can change over time, for example to comply with legal requirements or to meet changing business needs. The most up-to-date version can be found on this website. In cases of material changes, we will also inform you in another appropriate way (for example via a pop-up notice or statement of changes on our website) prior to the changes becoming effective.

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