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common approach needed to successfully implement DORA  Digital Operational
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enforcement trends – insights from AFME LondonBoth banks and regulators say a
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PRIVACY

PRIVACY STATEMENT

CORLYTICS is dedicated to protecting the confidentiality and privacy of
information entrusted to it. As part of this obligation, CORLYTICS is committed
to the protection of personal information that has been collected online.

Generally, our intent is to collect only the minimum required level of personal
information from licensed platform users and online visitors so that we can
offer information and/or services to those individuals or offer information
about employment opportunities. Please review this Privacy Statement to learn
more about how CORLYTICS collect, use, share and protect the personal
information provided to us via our Client Platform
(https://app.corlytics.com/login), Website (www.corlytics.com), and RED App
(https://corlytics.com/corlytics-red/).

Personal data will be collected, used, and disclosed by CORLYTICS in accordance
with the requirements and prohibitions of applicable laws and regulations.

GDPR AND THE LAWFUL BASIS FOR PROCESSING USER’S DATA.

When CORLYTICS processes user’s personal information, CORLYTICS are required to
have a legal basis for doing so. There are various legal bases on which
CORLYTICS may rely, depending on what personal information is processed and why.

The legal bases CORLYTICS may rely on include:

 * To Perform a Contract: where the processing is necessary for the performance
   of contractual obligations and services.
 * Consent: where users have given clear consent for to process their personal
   information for a specific purpose.
 * Legitimate Interest: where use of user’s personal information is for
   legitimate business purpose or to support a legitimate interest such as
   administering user accounts, login credentials and providing users with
   information on products and services.

USER’S RIGHTS

Under the General Data Protection Regulation (GDPR) users have rights in
relation to their personal information and personal data. These rights include:

 * Right of Access: Users have the right to request a copy of their personal
   data.
 * Right of Rectification: Users have the right to correct their data if it is
   inaccurate or incomplete without undue delay.
 * Right of Erasure (Right to be Forgotten): In certain circumstances users can
   ask for their data to be erased, e.g., where it is no longer necessary for
   CORLYTICS to hold a user’s personal data for the administration of their
   account.
 * Right to Restriction: In certain circumstances users have the right to
   restrict processing e.g., where the accuracy of their data is contested or in
   other circumstances proscribed by law.
 * Right of Portability: Users have the right to have their data transferred to
   them in a structured, commonly used, and machine-readable format.
 * Right to Object: Users have the right to object to certain types of
   processing such as direct marketing and automated processing, including
   profiling.

The above rights are not absolute and may be limited where it is necessary to
protect competing rights and the rights of others. CORLYTICS reserves the right,
where permitted by law, to verify a user’s identity.

WHAT KIND OF PERSONAL INFORMATION DOES CORLYTICS COLLECT?

In the course of our business, CORLYTICS may collect personal data about users
from the following sources:

 * From applications or other forms of communication CORLYTICS receive from
   users;
 * From CORLYTICS Website;
 * From Client organisations when they arrange user licenses and access to our
   products and services.

The personal information provided to CORLYTICS by licensed users consists of:

 1. Name
 2. Email Address
 3. Password

HOW DOES CORLYTICS USE THE PERSONAL DATA COLLECTED?

CORLYTICS uses the data collected to assist in providing products and services
to users, to provide users with information about those products and services
and for other legitimate business purposes.

The personal information required for access to CORLYTICS web applications
includes:

 * A users Name is required in order to provide support to user and so CORLYTICS
   can distinguish between users.
 * A users Email Address us used to uniquely identify users in our web
   applications.  It is also required to enable users to receive emails,
   notification, reports, and alerts from our web applications.
 * A Password is required to secure each user’s account.  After a user’s first
   successful login, CORLYTICS has no knowledge of each user’s password.  It is
   stored using non-reversible encryption.

HOW DOES CORLYTICS SAFEGUARD THE PERSONAL DATA COLLECTED?

CORLYTICS maintains electronic and procedural safeguards designed to protect
user’s personal data from unauthorised access or intrusion. These measures
include encryption, user access security measures and information security
controls. All CORLYTICS employees and contractors receive annual training
regarding CORLYTICS privacy and information security policies and procedures.

WHO HAS ACCESS TO THE PERSONAL INFORMATION CORLYTICS COLLECT?

CORLYTICS limits access to personal information to those employees, contractors,
business partners or agents who require such access in connection with providing
products or services to users or for other legitimate business purposes.

WHERE DOES CORLYTICS STORE THE PERSONAL INFORMATION COLLECTED?

CORLYTICS securely stores all client personal information in an encrypted
cloud-based data centre geographically located in Dublin, Ireland.

INTERNATIONAL DATA TRANSFERS

CORLYTICS may need to store and process user’s personal data in a non-European
Economic Area (EEA) country where CORLYTICS have operations. CORLYTICS may be
required to send personal data to recipients in countries other than the country
in which it is collected. Where these non-EEA countries have different data
protection laws, CORLYTICS will take measures to ensure users personal data
remains protected.

CORLYTICS USE OF COOKIES ON OUR WEBSITE

A cookie is a small text file which is placed onto a user’s device (e.g.,
computer, smartphone, or other electronic device) when users access our Client
platform or website. CORLYTICS uses cookies on our website. Cooked allow
CORLYTICS to recognise users, user devices and store information about user
preferences and past actions.

CONSENT TO USE COOKIES AND CHANGE SETTINGS

CORLYTICS will ask for a user’s permission (Consent) to place cookies or other
similar technologies on user’s devices, except where they are essential for
CORLYTICS to provide users with a service that they have requested.

Users can withdraw their consent to the use of cookies and manage their cookies
preferences by selecting the cookies policy button at the bottom right of the
CORLYTICS website.

For more information, you can find CORLYTICS Cookies Policy
at www.corlytics.com/cookie-policy/

PRIVACY NOTICE UPDATES

This Privacy Notice is subject to change. Please review this notice
periodically. All changes are effective from the date of publication.

CORLYTICS SUPPLEMENTAL PRIVACY STATEMENT FOR CONTENT DISTRIBUTED BY CORLYTICS

This supplemental Privacy Statement governs external, third party content
(informational content) republished and distributed via CORLYTICS Client
Platform (https://app.corlytics.com/login), and RED App
(https://corlytics.com/corlytics-red/)

WHY DOES CORLYTICS PUBLISH INFORMATIONAL CONTENT?

CORLYTICS republishes publicly available content sourced from external third
parties such as Financial Regulators, Prudential Regulators, Central Banks,
Fining Authorities, and Industry Bodies. For each notice republished CORLYTICS
acknowledges the original source, URL, and associated copyright of each notice
and original source. CORLYTICS also curates and produces summarised analysis of
these notices.

These sources publish regulatory enforcement notices levied against firms and
private individuals which may include personal information on private
individuals. CORLYTICS republishes and distributes these regulatory enforcement
notices as informational content via the Corlytics Platform and RED App. This
informational content provides the basis for Corlytics Regulatory Risk products
and services.

HOW DOES CORLYTICS OBTAIN INFORMATIONAL CONTENT AND WHAT TYPES OF INFORMATIONAL
CONTENT ARE PUBLISHED?

CORLYTICS obtains informational content (i) under license from the original
source, (ii) with authorisation from the original source, or (iii) where the
content is publicly available or in the public domain.

Where informational content is sourced from regulatory enforcement notices
against private individuals the following personal information may be included
in the original source publication: (i) name, (ii) occupation/qualifications,
(iii) employer/employment history, (iv) job title/function (v) period of
misconduct/disciplinary history, (vi) Jurisdiction/Regulator that brought the
enforcement action against an individual, (vii) monetary penalty imposed, and
(viii) non-monetary penalty imposed.

WHAT IF A PRIVATE INDIVIDUAL WISHES TO CORRECT OR REMOVE PERSONAL INFORMATION
CONTAINED IN CORLYTICS INFORMATIONAL CONTENT?

CORLYTICS is not the original publisher or source of the informational content.
CORLYTICS is not obliged to change or delete the substance of the original
content, as it relates to personal information, unless requested to do so under
a verified request from the original source or publisher of the regulatory
enforcement action.

Should a private individual wish to correct or remove their personal information
they should contact the original source or publisher of the regulatory
enforcement action.

Corlytics Ltd,
Registered in Ireland
no: 535110
VAT no. IE3240106LH

Corlytics Ltd,
Nexus Building,
Belfield Office Park
Clonskeagh,
Dublin D04 V2N9
Ireland

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