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PRIVACY POLICY

Last Updated: September 8, 2023

In order to ensure transparency and give you more control over your personal
information, this privacy policy (“Privacy Policy”) governs how we, Shield
Financial Compliance Ltd (together, “Shield FC” “we”, “our” or “us”) use,
collect and store personal data we collect or receive from or about you (“you”)
such as in the following use cases:

 * When you browse or visit our website, https://www.shieldfc.com/ (“Website”);
 * When you make use of, or interact with, our Website
   1. When you request to schedule a demo
   2. When you contact us

 3. When we process your job application

 * When you make use of, or interact with, our platform (“Platform”).
   1. When you create an account and when you log in
 * When you attend a marketing event and provide us with your personal data
 * When you exchange business cards with us

 * When we use the personal data of our customers (e.g. contact details)
 * When we use the personal data of our resellers, distributors, agents and/or
   finders (e.g. contact details)
 * When we use the personal data of our service providers (e.g. contact details)
 * When you interact with us on our social media profiles (e.g., Facebook,
   Instagram, Twitter, LinkedIn)

Please read this Privacy Policy carefully, so you can fully understand our
practices in relation to personal data. “Personal data” or “personal
information” means any information that can be used, alone or in combination
with other data, to uniquely identify an individual. Please note that this is a
master privacy policy and some of its provisions only apply to individuals in
certain jurisdictions.

Important note: Nothing in this Privacy Policy is intended to limit in any way
your statutory right, including your rights to a remedy or means of enforcement.

Table of contents:

 1.  What information we collect, why we collect it, and how it is used
 2.  How we protect and retain your personal data
 3.  How we share your personal data
 4.  Additional information regarding transfers of personal data
 5.  Your privacy rights
 6.  Use by children
 7.  Interaction with third-party products
 8.  Log files
 9.  Analytic tools
 10. Specific provisions applicable under California privacy law
 11. How to contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you
to check back periodically for the latest version of this Privacy Policy.  If we
implement significant changes to the use of your personal data in a manner
different from that stated at the time of collection, we will notify you by
posting a notice on our Website or by other means.

 1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Specific personal data we collect Why is the personal data collected and for
what purposes?Legal basis (GDPR only, if applicable)Third parties with whom we
share your personal dataRetention period Consequences of not providing personal
dataWhen you browse or visit our WebsiteData on how the Website is accessed and
used (“Usage Data”) in particular:·       IP address·       browser type·      
browser version·       the pages of the Website that you visit, the time and
date of your visit, the time spent on those pages·       unique device
identifiers·       other diagnostic data·       Cookies, analytic tools and log
filesFor more information, please read our cookies policy belowWe may use and
store information about your location if you give us permission to do so
(“Location Data”). You can enable or disable location services when you use our
Service at any time by way of your device settings.·       To gather analysis or
valuable information so that we can improve our Website·       To monitor the
usage of our Website·       To detect, prevent and address technical
issues·       To provide features of our Service, to improve and customize our
Service·       Consent·       Legitimate interest (e.g., essential cookies)3rd
party platforms such as for the following purposes:Google Analytics – website
analytics Google AdWords -Marketing HubSpot email communications and
CRM Facebook Advertising – Marketing LinkedIn Campaign Manager –
MarketingTwitter Advertising – Marketing    For more information, please read
our cookies policy below ·       Cannot gather analysis or valuable information
so that we can improve our Website·       Cannot monitor the usage of our
Website·       Cannot detect, prevent and address technical issues·      
Certain Website features may not be availableRead more about the purposes of
each cookie belowWhen you request a demo·       First name·       Last
name·       Email address·       Company name·       Job function·      
Country/ region ·       To be able to provide you with a demo of our
platform·       To communicate with you when coordinating and providing the
demo Legitimate interest (to provide you a demo)Processing is necessary for the
performance of a contract (i.e. license agreement) to which the data subject is
a party or in order to take steps at the request of the data subject prior to
entering into a contract3rd party platforms such as for the following
purposes: Google AdWords -Marketing HubSpot email communications and
CRM Facebook Advertising – Marketing LinkedIn Campaign Manager –
MarketingTwitter Advertising – MarketingUntil we no longer need the Information
and proactively delete it or you send a valid deletion request. Please note that
we may retain it for a longer or shorter period in accordance with data
retention laws.Cannot provide you a demoCannot communicate with you when
coordinating and providing the demoFull nameEmail addressCompany nameJob
functionCountry/ region  To send you marketing communicationsConsentLegitimate
interest (e.g. marketing) 3rd party platforms such as for the following
purposes:Google AdWords -Marketing HubSpot email communications and CRM Facebook
Advertising – Marketing LinkedIn Campaign Manager – Marketing Twitter
Advertising – MarketingUntil we no longer need the Information and proactively
delete it or you send a valid deletion request. Please note that we may retain
it for a longer or shorter period in accordance with data retention laws.Cannot
send you marketing communications  When you contact us by email·       Full
name·       Email address·       Any other information that you decide to
provide/supply us ·       To receive, process and respond to your
requestLegitimate interest (i.e. to respond to requests)Processing is necessary
for the performance of a contract (i.e. license agreement) to which the data
subject is a party or in order to take steps at the request of the data subject
prior to entering into a contract3rd party platforms such as for the following
purposes: Google AdWords -Marketing HubSpot email communications and
CRM Facebook Advertising – Marketing LinkedIn Campaign Manager –
MarketingTwitter Advertising – MarketingUntil we no longer need the Information
and proactively delete it or you send a valid deletion request. Please note that
we may retain it for a longer or shorter period in accordance with data
retention laws.·       Cannot receive, process and respond to your
request·       Full name·       Email address ·       To send you marketing
communications·       Consent·       Legitimate interest (e.g.
marketing) 3rd party platforms such as for the following purposes: Google
AdWords -Marketing HubSpot email communications and CRM Facebook Advertising –
Marketing LinkedIn Campaign Manager – MarketingTwitter Advertising –
MarketingUntil we no longer need the Information and proactively delete it or
you send a valid deletion request. Please note that we may retain it for a
longer or shorter period in accordance with data retention laws.·       Cannot
send you marketing communicationsWhen we process your job application·      
Full name·       Email address·       CV/cover letter·       Any other
information that you decide to provide/supply us ·       To assess you as a
candidate·       To analyze your application Processing is necessary for the
performance of a contract to which the data subject is a party or in order to
take steps at the request of the data subject prior to entering into a contract
(i.e. employment contract).Legitimate interest (e.g. to assess you as a
candidate).3rd party platforms such as for the following purposes:  HubSpot
email communications and CRM Until we no longer need the Information and
proactively delete it or you send a valid deletion request. Please note that we
may retain it for a longer or shorter period in accordance with data retention
laws. When you attend a marketing event and provide us with your personal
data·       Full name·       Job title·       Email address·       Company
name·       Phone number·       Any other information that you would provide
us ·       To establish a business connection·       To send you marketing
communications·       Consent·       Legitimate interest (e.g., to establish a
business connection)3rd party platforms such as for the following
purposes:Google AdWords -Marketing HubSpot email communications and CRM Facebook
Advertising – Marketing LinkedIn Campaign Manager – MarketingTwitter Advertising
– MarketingUntil we no longer need the Information and proactively delete it or
you send a valid deletion request. Please note that we may retain it for a
longer or shorter period in accordance with data retention laws.·       Cannot
establish a business connection·       Cannot send you marketing
communicationsWhen you exchange business cards with us·       Full name·      
Job title·       Email address·       Company name·       Phone number·      
Any other information that you would provide us ·       To establish a business
connection·       To send you marketing communicationsConsentLegitimate interest
(e.g., to establish a business connection)3rd party platforms such as for the
following purposes:Google AdWords -Marketing HubSpot email communications and
CRM Facebook Advertising – Marketing LinkedIn Campaign Manager –
Marketing Twitter Advertising – MarketingUntil we no longer need the Information
and proactively delete it or you send a valid deletion request. Please note that
we may retain it for a longer or shorter period in accordance with data
retention laws.·       Cannot establish a business connection·       Cannot send
you marketing communicationsWhen we use the personal data of our customers (e.g.
contact details)·       Full name·       Email address·       Phone
number·       Company name and details·       Payment information·       Any
other information that you decide to provide/supply us·       To provide our
products and services·       To perform the applicable agreement·       To
communicate with our customers/clients·       Processing is necessary for the
performance of a contract to which our customer is a party·       Compliance
with a legal obligation (e.g. tax laws, bookkeeping laws, etc.)·      
Legitimate interest (e.g. send you contract-related communications)3rd party
platforms such as for the following purposes:Google AdWords -Marketing HubSpot
email communications and CRM Facebook Advertising – Marketing LinkedIn Campaign
Manager – MarketingTwitter Advertising -MarketingUntil we no longer need the
Information and proactively delete it or you send a valid deletion request.
Please note that we may retain it for a longer or shorter period in accordance
with data retention laws.  ·       Cannot provide our products and
services·       Cannot perform the applicable agreement·       Cannot
communicate with our customers/clients When we use the personal data of our
service providers resellers, distributors, agents and/or finders (e.g. contact
details) ·       Full name·       Email address·       Phone number·      
Company name·       Any other information that you decide to provide/supply
us·       To contact our service providers, resellers, distributors, agents
and/or finders·       To perform the applicable agreement Processing is
necessary for the performance of a contract (i.e. Services Agreement) to which
the data subject is a party or in order to take steps at the request of the data
subject prior to entering into a contract.Legitimate interest (e.g. perform the
contract, send contract-related communications)3rd party platforms such as for
the following purposes:Google AdWords -Marketing HubSpot email communications
and CRM Facebook Advertising – Marketing LinkedIn Campaign Manager –
MarketingTwitter Advertising – MarketingUntil we no longer need the Information
and proactively delete it or you send a valid deletion request. Please note that
we may retain it for a longer or shorter period in accordance with data
retention laws.  ·       Cannot communicate with you·       Cannot perform the
applicable agreementWhen you interact with us on our social media profiles
(e.g., Facebook, Instagram, Twitter, LinkedIn)·       Full name·       Email
address·       Social media channel·       Any other data you decide to
provide/supply·       To respond to your requests in our social media
channels·       Legitimate interest (e.g. respond to your requests in our social
media channels)3rd party platforms such as for the following purposes: HubSpot
email communications and CRM Facebook Advertising – Marketing LinkedIn Campaign
Manager – MarketingTwitter Advertising – MarketingUntil we no longer need the
Information and proactively delete it or you send a valid deletion request.
Please note that we may retain it for a longer or shorter period in accordance
with data retention laws.Cannot respond to your request in our social media
channels·       Full name·       Email address·       To send you marketing
communications·       Consent·       Legitimate interest (e.g.,
marketing)3rd party platforms such as for the following purposes:  HubSpot email
communications and CRM Until we no longer need the Information and proactively
delete it or you send a valid deletion request. Please note that we may retain
it for a longer or shorter period in accordance with data retention laws.·      
Cannot send you marketing communications

Finally, please note that some of the abovementioned personal data will be used
for detecting, taking steps to prevent, and prosecution of fraud or other
illegal activity, to identify and repair errors, to conduct audits, and for
security purposes. Personal data may also be used to comply with applicable
laws, with investigations performed by the relevant authorities, law enforcement
purposes, and/or to exercise or defend legal claims. In certain cases, we may or
will anonymize or de-identify your personal data and further use it for internal
and external purposes, including, without limitation, to improve the services
and for research purposes. “Anonymous Information” means information which does
not enable identification of an individual user, such as aggregated information
about the use of our services. We may use Anonymous Information and/or disclose
it to third parties without restrictions (for example, in order to improve our
services and enhance your experience with them).

Read our full Cookie Policy here

 2. HOW WE PROTECT AND RETAIN YOUR INFORMATION

 * Security. We have implemented appropriate technical, organizational and
   security measures designed to protect your personal data. However, please
   note that we cannot guarantee that the information will not be compromised as
   a result of unauthorized penetration to our servers. As the security of
   information depends in part on the security of the computer, device or
   network you use to communicate with us and the security you use to protect
   your user IDs and passwords, please make sure to take appropriate measures to
   protect this information.

 * Retention of your personal data. In addition to the retention periods
   mentioned above, in some circumstances, we may store your personal data for
   longer periods of time, for example (i) where we are required to do so in
   accordance with legal, regulatory, tax or accounting requirements, or (ii)
   for us to have an accurate record of your dealings with us in the event of
   any complaints or challenges, or (iii) if we reasonably believe there is a
   prospect of litigation relating to your personal data or dealings. We have an
   internal data retention policy to ensure that we do not retain your personal
   data perpetually. Regarding the retention of cookies, you can read more in
   our cookie policy below.

 3. HOW WE SHARE YOUR PERSONAL DATA

 In addition to the recipients described above, we may share your personal data
as follows:

 * With our business partners, such as resellers, with whom we jointly offer
   products or services. We may also share Personal Data with our affiliated
   companies.
 * To the extent necessary, with regulators, courts or competent authorities, to
   comply with applicable laws, regulations and rules (including, without
   limitation, federal, state or local laws), and requests of law enforcement,
   regulatory and other governmental agencies or if required to do so by court
   order;
 * If in the future, we sell or transfer, or we consider selling or
   transferring, some or all of our business, shares or assets to a third party,
   we will disclose your personal data to such third party (whether actual or
   potential) in connection with the foregoing events to the maximum extent
   permitted under applicable laws;
 * In the event that we are acquired by, or merged with, a third party entity,
   or in the event of bankruptcy or a comparable event, we reserve the right to
   transfer, disclose or assign your personal data in connection with the
   foregoing events to the maximum extent permitted under applicable laws;
   and/or
 * Where you have provided your consent to us sharing or transferring your
   personal data (e.g., where you provide us with marketing consents or opt-in
   to optional additional services or functionality).

 4. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

 * Storage: We store personal data on AWS’s servers in North Virginia – US –
   subject to standard contractual clauses included in our agreement with AWS.

 * Internal transfers: to the extent we will conduct transfers within the Shield
   FC group, we will, to the extent required under applicable data protection
   law, be covered by an internal processing agreement entered into by members
   of the Shield FC (an intra-group agreement) which contractually obliges each
   member to ensure that personal data receives an adequate and consistent level
   of protection wherever it is transferred to.

 * External transfers: Where we transfer your personal data outside of EU/EEA,
   we rely on i) Adequacy Decisions as adopted by the European Commission on the
   basis of Article 45 of Regulation (EU) 2016/679 (GDPR) (for example, when we
   access from Israel), or ii) Standard Contractual Clauses issued by the
   European Commission.

 5. YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT

 * Rights: The following rights (which may be subject to certain exemptions or
   derogations) shall apply to certain individuals (some of which only apply to
   individuals protected by the GDPR):

 * You have a right to access personal data held about you. Your right of access
   may normally be exercised free of charge, however, we reserve the right to
   charge an appropriate administrative fee where permitted by applicable law;
 * You have the right to request that we rectify any personal data we hold that
   is inaccurate or misleading;
 * You have the right to request the erasure/deletion of your personal data
   (e.g. from our records). Please note that there may be circumstances in which
   we are required to retain your personal data, for example for the
   establishment, exercise or defense of legal claims as mentioned in Section 3
   above;
 * You have the right to object, to or to request restriction, of the
   processing;
 * You have the right to data portability. This means that you may have the
   right to receive your personal data in a structured, commonly used and
   machine-readable format and that you have the right to transmit that data to
   another controller;
 * You have the right to object to profiling;
 * You have the right to withdraw your consent at any time. Please note that
   there may be circumstances in which we are entitled to continue processing
   your data, in particular, if the processing is required to meet our legal and
   regulatory obligations. Also, please note that the withdrawal of consent
   shall not affect the lawfulness of processing based on consent before its
   withdrawal;
 * You also have a right to request certain details of the basis on which your
   personal data is transferred outside the European Economic Area, but data
   transfer agreements and/or other details may need to be partially redacted
   for reasons of commercial confidentiality;
 * You have a right to lodge a complaint with your local data protection
   supervisory authority (i.e., your place of habitual residence, place or work
   or place of alleged infringement) at any time or before the relevant
   institutions in your place of residence. We ask that you please attempt to
   resolve any issues with us before you contact your local supervisory
   authority and/or relevant institution.

 * You can exercise your rights by contacting us at info@shieldfc.com. Subject
   to legal and other permissible considerations, we will make every reasonable
   effort to honor your request promptly in accordance with applicable law or
   inform you if we require further information in order to fulfill your
   request. When processing your request, we may ask you for additional
   information to confirm or verify your identity and for security purposes,
   before processing and/or honoring your request. We reserve the right to
   charge a fee where permitted by law, for instance, if your request is
   manifestly unfounded or excessive. In the event that your request would
   adversely affect the rights and freedoms of others (for example, would impact
   the duty of confidentiality we owe to others) or if we are legally entitled
   to deal with your request in a different way than initially requested, we
   will address your request to the maximum extent possible, all in accordance
   with applicable law.

 * Deleting your account: Should you ever decide to delete your account, you may
   do so by emailing info@shieldfc.com. If you terminate your account, any
   association between your account and personal data we store will no longer be
   accessible through your account. However, given the nature of sharing on
   certain services, any public activity on your account prior to deletion will
   remain stored on our servers and will remain accessible to the public.

 6. USE BY CHILDREN

We do not offer our products or services for use by children and, therefore, we
do not knowingly collect personal data from, and/or about children under the age
of eighteen (18). If you are under the age of eighteen (18), do not provide any
personal data to us without the involvement of a parent or a guardian. For the
purposes of the GDPR, we do not intend to offer information
society services directly to children. In the event that we become aware that
you provide personal data in violation of applicable privacy laws, we reserve
the right to delete it. If you believe that we might have any such information,
please contact us at info@shieldfc.com.

 7. INTERACTION WITH THIRD PARTY PRODUCTS

We may enable you to interact with third-party websites, mobile software
applications and products or services that are not owned or controlled by us
(each a “Third Party Service”). We are not responsible for the privacy practices
or the content of such Third Party Services. Please be aware that Third Party
Services can collect Personal Data from you. Accordingly, we encourage you to
read the terms and conditions and privacy policies of each Third-Party Service.

 8. LOG FILES

We use log files. The information inside the log files includes internet
protocol (IP) addresses, type of browser, Internet Service Provider (ISP),
date/time stamp, referring/exit pages, clicked pages and any other information
your browser may send to us. We use such information to analyze trends,
administer the Website, track users’ movement around the Website, and gather
demographic information.

 9. ANALYTIC AND BEHAVIOURAL REMARKETING TOOLS

 * Google Analytics. The Website uses a tool called “Google Analytics” to
   collect information about the use of the Website. Google Analytics collects
   information such as how often users visit this Website, what pages they visit
   when they do so, and what other websites they used prior to coming to this
   Website. We use the information we get from Google Analytics to maintain and
   improve the Website and our products. We do not combine the information
   collected through the use of Google Analytics with the personal information
   we collect. Google’s ability to use and share information collected by Google
   Analytics about your visits to this Website is restricted by the Google
   Analytics Terms of Service, available
   at https://marketingplatform.google.com/about/analytics/terms/us/, and the
   Google Privacy Policy, available at http://www.google.com/policies/privacy/.
   You may learn more about how Google collects and processes data specifically
   in connection with Google Analytics
   at http://www.google.com/policies/privacy/partners/. You may prevent your
   data from being used by Google Analytics by downloading and installing the
   Google Analytics Opt-out Browser Add-on, available
   at https://tools.google.com/dlpage/gaoptout/.

 * Twitter. Twitter remarketing service is provided by Twitter Inc. You can
   opt-out from Twitter’s interest-based ads by following their
   instructions: https://support.twitter.com/articles/20170405. You can learn
   more about the privacy practices and policies of Twitter by visiting their
   Privacy Policy page: https://twitter.com/privacy.

 * Facebook remarketing service is provided by Facebook Inc. You can learn more
   about interest-based advertising from Facebook by visiting this
   page: https://www.facebook.com/help/164968693837950. To opt-out from
   Facebook’s interest-based ads, follow these instructions from
   Facebook: https://www.facebook.com/help/568137493302217. Facebook adheres to
   the Self-Regulatory Principles for Online Behavioural Advertising established
   by the Digital Advertising Alliance. You can also opt-out from Facebook and
   other participating companies through the Digital Advertising Alliance in the
   USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of
   Canada in Canada http://youradchoices.ca/, or the European Interactive
   Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or
   opt-out using your mobile device settings. For more information on the
   privacy practices of Facebook, please visit Facebook’s Data
   Policy: https://www.facebook.com/privacy/explanation.

 * LinkedIn Ads. LinkedIn Ads is provided by LinkedIn Corporation. You can learn
   more about LinkedIn’s interest-based advertising by visiting this
   page: https://www.linkedin.com/help/linkedin/answer/85787. You can opt-out
   from LinkedIn Ads by following their instructions
   at: https://www.linkedin.com/help/linkedin/answer/62931/manage-advertising-preferences?lang=en.
   You can learn more about the privacy practices and policies of LinkedIn by
   visiting their Privacy Policy
   page: https://www.linkedin.com/legal/privacy-policy.

We reserve the right to remove or add new analytic tools.

 10. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW

 * Our California Do Not Track Notice:Do Not Track (“DNT”) is a privacy
   preference that users can set in certain web browsers. Please note that we do
   not respond to or honor DNT signals or similar mechanisms transmitted by web
   browsers, but we may allow third parties, such as companies that provide us
   with analytics tools, to collect personally identifiable information about an
   individual consumer’s online activities over time and across different web
   sites when a consumer uses the Services.

 * Deletion of Content from California Residents: If you are a California
   resident under the age of 18 and a registered user, California Business and
   Professions Code Section 22581 permits you to remove content or personal
   information you have publicly posted.  If you wish to remove such content or
   personal information and you specify which content or personal information
   you wish to be removed, we will do so in accordance with applicable law. 
   Please be aware that after removal you may not be able to restore removed
   content. In addition, such removal does not ensure complete or comprehensive
   removal of the content or personal information you have posted and that there
   may be circumstances in which the law does not require us to enable removal
   of content.

 * Your Choices.You have certain choices about your Personal Information. Where
   you have consented to the processing of your Personal Information, you may
   withdraw that consent at any time and prevent further processing by
   contacting us as described in this Privacy Policy. Even if you opt out, we
   may still collect and use non-Personal Information regarding your activities
   on our services and for other legal purposes as described above. While we
   cannot guarantee privacy perfection, we will address any issue to the best of
   our ability as soon as possible. We will process such requests in accordance
   with applicable laws. To protect your privacy, we will take steps to verify
   your identity before fulfilling your request.

 11. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with
this notice and the data protection laws, or if you wish to exercise your
rights, we encourage you to first contact us at info@shieldfc.com.

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