Privacy Policy and Confidentiality Policy

Fintech SCB — Privacy, Confidentiality & Client Data Protection Policy

This document sets out the principles and measures adopted by Fintech SCB LLC to ensure the confidentiality, security and protection of client information.

1. Introduction

FINTECH SCB (“FINTECH SCB”, the “Company”) places primary importance on the confidentiality, security and protection of information relating to its clients, prospective clients, beneficial owners, counterparties and collaborators.

The Company applies a principle of strict professional secrecy to all information acquired in the course of its financial, advisory, intermediation and assistance services.

FINTECH SCB processes information solely for specified, legitimate and documented purposes and limits access to authorised staff and collaborators on a need-to-know basis.

2. Principle of utmost confidentiality

FINTECH SCB treats information concerning its clients and their transactions as confidential information. The Company undertakes to:

maintain the utmost confidentiality regarding client information;
not disclose information to unauthorised parties;
restrict access to data exclusively to persons with an actual professional need;
adopt adequate technical and organisational measures to prevent unauthorised access, use, alteration or disclosure;
protect the confidentiality of communications and financial documentation;
maintain internal procedures aimed at protecting data throughout the entire lifecycle of the relationship.

3. Processing of financial information

Information concerning liquid assets, wealth, investments, transactions, banking relationships, corporate activities and financial documentation is processed with the highest level of confidentiality compatible with applicable regulatory obligations.

FINTECH SCB applies internal procedures designed to prevent the unauthorised dissemination of such information.

Information is not used for purposes other than those for which it was lawfully collected, unless required or permitted by applicable law.

4. Access to information

Access to client information is limited to authorised staff and to professionals or suppliers who require such information to perform their respective functions.

Where necessary, such parties are bound by contractual or professional confidentiality obligations.

The Company applies the need-to-know principle, whereby each person may access only the information required to carry out their duties.

5. Disclosure to banks and counterparties

Where the service requested by the client involves banks, financial intermediaries, professionals, advisors or other authorised counterparties, FINTECH SCB may disclose only the information strictly necessary to perform the service.

11. Confidentiality of communications

Communications between the client and FINTECH SCB are considered confidential.

The Company adopts procedures aimed at ensuring that communications are accessible exclusively to authorised recipients.

The client is invited to use only the official channels indicated by the Company for sending confidential documentation.

12. Non-disclosure principle

FINTECH SCB does not voluntarily disclose information relating to its clients to unauthorised third parties.

13. Company commitment

FINTECH SCB considers client trust an essential element of its operating model.

The Company is committed to ensuring a high standard of:

The protection of client information is a permanent principle of the professional relationship.

CONFIDENTIALITY — DATA PROTECTION — INFORMATION SECURITY — PROFESSIONAL SECRECY

Confidentiality contacts

For any request concerning the processing of information, please write to clientsupport@fintechscb.com — Fintech SCB LLC, 900 Brickell Bay Drive, Miami, FL 33131, USA.

CONFIDENTIALITY CLAUSE

FINTECH SCB guarantees the utmost confidentiality of information relating to its clients and the activities carried out on their behalf. No information will be voluntarily disclosed to unauthorised persons.