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AMMERIS PRIVACY POLICY

Last modified: August 28, 2018

Ammeris is committed to your privacy.

Ammeris ("we", "us" or "our") is sensitive to the privacy concerns of the users of our website, www.ammeris.com (the "Website" or "Site"), and services made available by us on the Site (the "Services") (each such person, "you") and our obligations with respect to data collected under applicable laws including, without limitation, the European Union's General Data Protection Regulation ("GDPR").

We have a policy of protecting the confidentiality and security of information we collect about you. We are providing you this notice to help you better understand what kinds of information we collect about you, the purposes for which information is intended to be processed and the circumstances in which that information may be disclosed to third parties. By accessing the Site and/or Services, you acknowledge and consent, to the maximum extent permitted by applicable law, that we may collect, use, disclose and share your Personal Data on the terms described in this Privacy Policy.

Who is Covered by the Privacy Policy?

This Privacy Policy applies to natural persons who are accessing and using the Site and/or Services, including prospective, current and former natural persons who have accessed, will access, have used or will use the Site and/or Services.

Personal Data may be collected from you by us through a variety of channels, including through your purchase of AMRS, your subscription to a personal account on the Site ("Site Account"), as well as through ongoing communications by mail, e-mail or telephone.

Sources of Non-Public Information

We collect and maintain non-public personal information of individuals ("Personal Data") from the following sources:

Information captured on the Site, including registration information and any information captured via "cookies" (including persistent and session "cookies");
Information we receive from you in conversations over the telephone, in voicemails, through written correspondence, via e-mail or other forms of communication; and
Information about your transactions with us or others.

Purpose of Collection of Personal Data

You have provided us (or will provide us from time to time) with Personal Data in connection with and for the purposes of access to and use of the Site and/or Services, including:

our acceptance, provision, administration and management of your Site Account and/or Services to you;
monitoring or recording any communications between you on the one part and us on the other part including telephone calls, for the purpose of verifying instructions, analysing, assessing and improving services, training and quality purposes, security and the prevention and detection of crime;
verification and background checks, including Know-Your-Customer checks, customer due diligence, credit checks, and such other checks as may be necessary in compliance with applicable laws, as well as managing and recovering debt;
archival of documents and records in both electronic and physical form for record keeping purposes, maintaining records of customer instructions, whether through phone recordings, hard copy documents, soft copy documents, instructions given via electronic means or SMS instructions;
conducting reporting and analysis related to the Site's operations;
conducting reporting and analysis related to the provisio of Services;
complying with our policies and procedures;
preventing, detecting and investigating crime, including fraud, monely laundering, terrorism and proliferation financing and any other form of financial crime, and analysing and managing other commercial risks; and
compliance with any applicable rules, laws and regulations, codes of practice, guidance or guidelines, including, without limitation, compliance with laws and regulations (local and foreign) which may apply to the Site, Site Account and/or Services, or to assist in law enforcement and investigations by relevant authorities (collectively, “Purposes”).

To the extent that the Personal Data of any individual is disclosed by you to us for the purposes of accessing the Site, Site Account and/or Services, you hereby warrant and undertake that the relevant consents required under all applicable data protection legislation (including without limitation the GDPR) have been obtained for the disclosure of their Personal Data to us and the subsequent use and disclosure of their Personal Data by us for the purposes set out in this Privacy Policy.

You also agree and acknowledge that the withdrawal of any consent provided to us hereunder relating to any Personal Data may result in our being unable to administer or manage your Site Account or otherwise provide our Services to you. In such event, we shall have the right to terminate your Site Account and/or the provision of Services to you, without prejudice to our rights and remedies against you in respect of any loss or damage arising in connection with such termination.

Disclosure of Personal Data

Except as otherwise set out in this Privacy Policy, we do not sell, trade, rent or otherwise disclose Personal Data to affiliates or to non-affiliates, without your express consent.

We do, or may, disclose Personal Data to third parties for the Purposes, and as may be required by law or for everyday business purposes, such as to process transactions, maintain Site Accounts, for the purposes of operating or administering the Site and/or Services, or to respond to court orders and legal investigations. We also provide such information to our attorneys, banks, auditors and other similar institutions, any person to whom we are under an obligation to make disclosure to under the requirements of any law binding us, the Site and/or the Services or under and for the purposes of any guidelines issued by any regulatory or other authorities with which we are expected to comply and service providers which provide services to us, such as telecommunications, information technology, payment, data processing, training, storage, archival, trade execution or other services as may be necessary to facilitate the acceptance, management and administration of the Site, your Site Account and/or Services to you, and to enable them to perform services on our behalf.

In addition, in the event we undergo any actual or prospective restructuring, sale or acquisition of any company or assets of ours, we may also disclose or transfer your Personal Data to any third party in connection with any such restructuring, sale or acquisition, actual or prospective.

In addition, where you have (at any time) provided us with your specific consent in accordance with applicable data protection laws and regulations, we may also provide certain of your Personal Data (including but not limited to your name, address, telephone number, social security number or financial condition information) to third-parties, such as broker-dealers, engaged in marketing activities on our behalf.

Security of Personal Data

We take our responsibility to protect the privacy and confidentiality of your Personal Data very seriously. We maintain appropriate physical, electronic and procedural safeguards to store and secure your Personal Data from unauthorised access, alteration and destruction.

Access to Personal Data

You have the right of access to, and to update, all your records held by us (whether on computer files or manually). A copy of your records will be provided to you if so requested, upon the payment of a modest administration charge to cover the costs of complying with such request. Requests should be made in writing to legal@ammeris.com.

Further Information

We reserve the right to change our privacy policies and this Privacy Policy as we see fit at any time and from time to time.

Who to contact with questions

If you have any questions about this Privacy Policy, please contact legal@ammeris.com.