PRIVACY POLICY

Last Updated: August 24, 2023

For purposes of this Privacy Policy, the term Bank means Paxum Bank Limited, having its registered
address at Centre Cross Lane, Roseau, Dominica.

At Paxum Bank, we take the privacy of our Clients very seriously. This privacy policy outlines how
we collect, use, and protect your personal information. By using our services and accepting this
policy, you consent to us collecting and using your information as described below.

Glossary

In this privacy policy, the following terms shall have the following meanings:
Client, Client, or User means a natural or legal person or another type of entity that registers for the
Service or uses the Service as a Client, i.e. you.
Personal data is any information about an identified or identifiable natural person.
Processing means any operation or set of operations which is performed on personal data, whether
or not by automated means, such as collection, recording, organization, structuring, storage,
adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or
otherwise making available, alignment or combination, restriction, erasure or destruction.
Data controller means the natural or legal person, public authority, agency or other body which,
alone or jointly with others, determines the purposes and means of processing personal data.
Data processor means a natural or legal person, public authority, agency or other body which
processes personal data on behalf of the data controller.
GDPR means the General Data Protection Regulation of the European Union.
CCPA means the California Consumer Privacy Act of the United States.
Website means www.paxumbank.com or www.paxum.com.
Sensitive personal data means personal data revealing racial or ethnic origin, political opinions,
religious or philosophical beliefs, trade union membership, genetic data, biometric data, data
concerning health or a natural persons sex life or sexual orientation.
Consent means any freely given, specific, informed and unambiguous indication of the data subjects
wishes by which they, by a statement or by an explicit affirmative action, signify agreement to the

Paxum Bank Limited

Tel.: 1-866-347-4781
Fax: 1-267-295-7389
processing of personal data relating to them.
Data subject means the individual to whom the personal data relates.
Third-party means a natural or legal person, public authority, agency or body other than the data
subject, controller, processor and persons who, under the direct authority of the controller or
processor, are authorized to process personal data.
Data breach means a breach of security leading to the accidental or unlawful destruction, loss,
alteration, or unauthorized disclosure of, or access to, personal data transmitted, stored, or
otherwise processed.
Privacy Notice means a statement or document describing how an organization collects, uses, and
shares personal data.
Privacy Shield means the framework for transatlantic exchanges of personal data between the
European Union and the United States.
Right to be forgotten means the right of a data subject to have their personal data erased by the
data controller.
Profiling means any form of automated processing of personal data consisting of the use of personal
data to evaluate certain personal aspects relating to a natural person, in particular, to analyze or
predict factors concerning that natural persons performance at work, economic situation, health,
personal preferences, interests, reliability, behaviour, location or movements.
Data portability means the right of a data subject to receive the personal data concerning them,
which they have provided to a controller, in a structured, commonly used and machine-readable
format. They have the right to transmit those data to another controller without hindrance.

1. Introduction

This privacy policy sets out how Paxum Bank collects, uses, and protects personal data per the
General Data Protection Regulation (GDPR), and the California Consumer Privacy Act (CCPA).

2. Personal Data We Collect

2.1. Categories of Personal Data

Paxum Bank Limited
Tel.: 1-866-347-4781
Fax: 1-267-295-7389
The Bank may collect the following categories of personal data:
Identifiers such as name, address, email address, telephone number, date of birth, and
government-issued identification numbers;
Financial information such as bank account numbers, credit card numbers, and transaction data;
Employment information such as job title, employer name, and salary information;
Internet and network activity such as browsing history, IP address, and device information; and
Other information that identifies or relates to an individual.
Sensitive personal data that is required to detect and prevent financial crime and other unlawful
activity.

If you visit the Banks website (Site) or the website of its Paxum.com brand for informational
purposes only, the Bank will not require you to provide any personal information. You will remain
anonymous unless you register for our services or otherwise disclose your identity. However, the
Bank may collect and store specific visitor data including, but not limited to, browser type, Internet
Protocol (IP) address, and geo-location information.

Other data may be collected in such cases as:

If an individual registers for an account with the Bank, the Bank will request information which
includes the individuals name, email address, physical address, country of residence, contact phone
numbers, date of birth, tax identification number, employment information, and the Bank may
request bank account details and credit and/or debit card details;
If an entity registers for an account with the Bank, the Bank will request information from certain
owners, directors and authorized individuals for the entity, which includes those individuals names,
email addresses, physical addresses, contact phone numbers, dates of birth, and
government-issued identification numbers;
Before a Client utilizes any of the Banks services and throughout our relationship with a Client, the
Bank may require a Client to provide additional information to verify an individuals identity, address
or other data to manage risk and compliance. We may also obtain information from third parties
providing services such as identity verification, fraud prevention and similar services;
If you choose to participate in a Client survey, the Bank may ask for your name, email address and
Paxum Bank Limited
Tel.: 1-866-347-4781
Fax: 1-267-295-7389
other information required by the particular survey; andIf you report a problem or submit a Client
review, the Bank will ask you to provide your name, email address, and account number.

2.2. Sources of Personal Data

The Bank may collect personal data directly from individuals, third-party service providers, and
publicly available sources, from the documentation you submit to us or information you submit to us
through our website or other means of electronic communication.

3. How We Use Personal Data

3.1. The Bank may use personal data for the following purposes:

Evaluating a Client for the Bank services a Client requests;

Registering a Client as a client and opening an account;
Contacting a Client to verify or reconfirm the accuracy of the information provided;
Facilitating payments and transactions as directed by a Client;
Confirming the existence and availability of funds;
Administering a Clients account;
Assisting in the provision of other services or products requested by a Client;
Resolving disputes and troubleshooting problems;
Preventing potentially fraudulent, prohibited or illegal activities and enforcing our contracts with a
Client;
Complying with legal processes such as subpoenas and court orders and performing other duties as
required by law;
Researching the demographics and behaviours of the Banks Clients; and
Reporting to law enforcement authorities if the Bank believes a crime has been committed.

3.2. Profiling and Automated Decision Making

Paxum Bank Limited

Tel.: 1-866-347-4781
Fax: 1-267-295-7389
We may use some instances of your data to customize our Services and the information we provide
to you and to address your needs - such as your country of address and transaction history. For
example, if you frequently send funds from one particular currency to another, we may use this
information to inform you of new product updates or features that may be useful for you. When we
do this, we take all necessary measures to ensure that your privacy and security are protected - and
we only use pseudonymized data where ever possible. This activity has no legal effect on you.

We may use Automated Decision Making (ADM) to improve your experience or to help detect and
fight financial crime. For example, we may use ADM to verify your identity documents or to confirm
the accuracy of the information you provided us to provide you with efficient service. None of our
ADM processes have a legal effect on you.

4. Legal Basis for Processing Personal Data

The Bank will only process personal data if it has a lawful basis. The legal bases for processing
personal data may include the following:
The individual gives consent for one or more specific purposes;
Performance of a contract with the individual;
Compliance with the Proceeds of Crime Act (2014) and associated regulations;
Compliance with other legal obligations; or
Legitimate interests pursued by the Bank or a third party.

5. Data Protection Principles

5.1. Lawfulness, Fairness, and Transparency

The Bank will process personal data lawfully, fairly, and transparently.

5.2. Purpose Limitation

Paxum Bank Limited

Tel.: 1-866-347-4781
Fax: 1-267-295-7389
The Bank will only collect personal data for specified, explicit, and legitimate purposes and will not
process personal data in a manner that is incompatible with those purposes.

5.3. Data Minimization

The Bank will only collect personal data that is adequate, relevant, and limited to what is necessary
for the purposes for which it is processed.

5.4. Accuracy

The Bank will take reasonable steps to ensure that personal data is accurate and up to date.

5.5. Storage Limitation

The Bank will only retain personal data for as long as necessary to fulfill the purposes for which it
was collected or as required by law. The Bank must keep all account data for seven (7) years
following the closure of an account or account application.

5.6. Integrity and Confidentiality

The Bank will process personal data in a manner that ensures appropriate security, including
protection against unauthorized or unlawful processing and against accidental loss, destruction, or
damage.

5.7. Individual Rights

Individuals have the following rights regarding their personal data:

The right to access their personal data held by the Bank;
The right to request correction or deletion of inaccurate data;
The right to object to the processing of their personal data;
Paxum Bank Limited
Tel.: 1-866-347-4781
Fax: 1-267-295-7389
The right to restrict processing of their personal data;
The right to data portability; and
The right to withdraw consent at any time.

5.8. Your Rights

GDPR

5.8.1. Under the GDPR, you have the following rights with respect to your personal data:
5.8.1.1. The right to be informed: You have the right to know how your personal data is being
processed and why.
5.8.1.2. The right of access: You have the right to access your personal data held by us. You can
exercise this right by making a request in writing to us.
5.8.1.3. The right to rectification: You have the right to rectify inaccurate or incomplete personal data
we hold on you. You can exercise this right by making a request in writing to us.
5.8.1.4. The right to erasure (right to be forgotten): You have the right to have your personal data
erased under certain circumstances. You can exercise this right by making a request in writing to us.
5.8.1.5. The right to restrict processing: You have the right to request the restriction or suppression
of your personal data. You can exercise this right by making a request in writing to us.
5.8.1.6. The right to data portability: You have the right to receive your personal data in a structured,
commonly used, and machine-readable format and to transmit that data to another controller.
5.8.1.7. The right to object: You have the right to object to the processing of your personal data in
certain circumstances.
5.8.1.8. The right to withdraw consent: If we rely on your consent to process your personal data, you
have the right to withdraw your consent at any time. This will not affect the lawfulness of our
processing based on your consent before its withdrawal. You grant us consent to process your
personal data by agreeing to this policy.

CCPA

Paxum Bank Limited

Tel.: 1-866-347-4781
Fax: 1-267-295-7389
5.8.2. Under the CCPA, you have the following rights with respect to your personal data:
5.8.2.1. The right to know: You have the right to know what personal information we collect, use,
disclose, and sell about you.
5.8.2.2. The right to delete: You have the right to request the deletion of your personal information.
5.8.2.3. The right to opt-out: You have the right to opt out of the sale of your personal information.
Note that Paxum Bank does not sell your personal information.
5.8.2.4. The right to non-discrimination: You have the right not to be discriminated against for
exercising your privacy rights under the CCPA.

5.9. Limitations

Paxum Bank reserves the right to restrict certain information being sent to you, which is not about
you should the Bank consider certain information a trade secret or if it infringes on another persons
privacy rights. For example, if you request a list of all Paxum Bank employees who have access to
your personal data, we will not be able to accommodate your request due to the privacy rights of
those employees.

Paxum Bank reserves the right to restrict certain information about you being sent to you if the Bank
determines that sending such information to you does not fall under the purview of your data rights
or if it is unlawful for the Bank to send information about you to you.

6. International Data Transfers

6.1. Transfer Mechanisms

The Bank may transfer personal data to countries outside Dominica, the EU/EEA, and the United
States, where data protection laws may offer a different level of protection than those in the regions
mentioned above. In such cases, the Bank will ensure that adequate safeguards are in place to
protect personal data, such as:

Paxum Bank Limited

Tel.: 1-866-347-4781
Fax: 1-267-295-7389
Standard Contractual Clauses (SCCs): the Bank will use SCCs as approved by the European
Commission or other relevant supervisory authorities.
Binding Corporate Rules (BCRs): where applicable, the Bank may use BCRs to ensure that
personal data transferred within the Banks group of companies are adequately protected.
Other Transfer Mechanisms: the Bank may use other transfer mechanisms recognized by applicable
data protection laws, such as the EU-U.S. Privacy Shield framework.

6.2. Data Subject Requests

Data subjects have the right to access their personal data, as well as to request the correction,
erasure, or restriction of processing of their personal data. Data subjects also have the right to
object to the processing of their personal data, as well as the right to data portability.
To exercise these rights, data subjects should contact the Banks Data Protection Officer (DPO)
using the contact details provided in section 10.

7. Data Security

7.1. Technical and Organizational Measures

7.1.1. The Bank is committed to ensuring the security and confidentiality of personal data. The Bank
will implement appropriate technical and organizational measures to protect personal data from
unauthorized access, accidental loss, destruction, or damage.
Such measures may include:
Access controls and authentication mechanisms to restrict access to personal data to authorized
personnel only.
Encryption of personal data in transit and at rest.
Regular backups and disaster recovery plans.
Monitoring and logging of access to personal data.
Employee training on data protection and information security.

Paxum Bank Limited

Tel.: 1-866-347-4781
Fax: 1-267-295-7389
7.2. Third-Party Service Providers

The Bank may engage third-party service providers to process personal data on its behalf, such as
IT service providers, cloud service providers, or payment processors. The Bank will ensure that such
third-party service providers offer sufficient guarantees to implement appropriate technical and
organizational measures to ensure the security of personal data.

The Bank will enter into written agreements with such third-party service providers that include
provisions requiring them to implement appropriate technical and organizational measures to ensure
the security of personal data and to process personal data only in accordance with the Banks
instructions.

7.3. How the Bank Protects your Personal Information

The Bank has implemented technical and managerial procedures to maintain accurate, current and
complete information as well as to protect personal information from loss, misuse or alteration when
it is under the Banks control.

Personally identifiable information will be stored on the Banks secure servers or third-party servers
in secure data centers. The Bank has ensured that or has confirmed that third parties maintaining
the servers have appropriate safeguards such as firewalls and data encryption and that proper
physical access controls to the files are enforced. The Bank authorizes access to personal
information only for those employees who require it to fulfill their job responsibilities.

Personal information is also password protected so that access is limited to Clients and those with
whom a Client shares their password, the Bank, and third-party access facilitated by the Bank in
relation to the performance of the services offered.

The Bank has also taken steps to protect the integrity of its Clients personal financial information
when they initiate a transaction on the Banks Site.
Paxum Bank Limited
Tel.: 1-866-347-4781
Fax: 1-267-295-7389
Despite the Banks reasonable efforts to protect personal information, the Bank cannot guarantee
that personal information will not be accessed, disclosed, altered or destroyed.

8. Data Retention

8.1. Because were a regulated financial institution, Paxum Bank is obliged to store some of your
personal and transactional data for up to 7 years following the closure of your account. Only a small
number of our employees can see that data, and theyll only look at it if they need to. We always
delete information that we no longer need. And everything we need to keep is subject to the highest
levels of security.

Please note: Retention periods could be subject to change, depending on where you live, changes
to regulatory requirements, or other legal obligations with which we need to comply.

8.2. Paxum Bank is required to retain all data associated with accounts determined to have been
opened for seven years following account closure.

For the purposes of data retention, Paxum Bank considers an account to be open once an
application for a Paxum Bank or Paxum.com account has been submitted. An account is not
required to be verified and active in order for it to be considered open. Submitting an account
application and agreeing to Paxum Banks Terms and Conditions, including this Privacy Policy,
renders the account open and subject to data retention.

8.3. In the event of identity theft, the Bank remains obligated to retain personal data submitted to the
Bank, regardless of the circumstances of the identity theft.

8.4. Basis of Retention: Even if you exercise your right to request data erasure vis--vis your personal
data held by Paxum Bank, we may not be able to accommodate your request to other legal
obligations of the Bank, including data retention for the purposes of complying with the Proceeds of
Crime Act (2014) and its associated regulations and amendments.
Paxum Bank Limited
Tel.: 1-866-347-4781
Fax: 1-267-295-7389
For example, if you wish to exercise your rights under GDPR to request the erasure of your data,
you should keep in mind that Paxum Bank is entitled to retain all records related to natural and legal
persons who apply for or who obtain a Paxum Bank account under:
Recital 19 of the GDPR
Article 6.1c of the GDPR
Article 6.1e of the GDPR
Article 17.3 of the GDPR

We are entitled to retain your personal data, including sensitive personal data, because we are
obliged to keep your data on file for a period of 7 years following the closure of your account to meet
our legal obligations under the Proceeds of Crime Act (2014) and associated legislation and
regulations.

Paxum Bank also reserves the right to refuse a data erasure request following the data retention
period in rare circumstances where it has a legal obligation to retain that data.

9. Contact Information

9.1. Data Protection Officer

The Bank has appointed a Data Protection Officer (DPO) who is responsible for overseeing the
Banks compliance with data protection laws and for addressing any inquiries or complaints
regarding the Banks processing of personal data.

The DPO can be contacted at:

[email protected], where the request is for Paxum Bank Services.
[email protected], where the request is for Paxum.com Services.

9.2. Other Contact Information

Paxum Bank Limited

Tel.: 1-866-347-4781
Fax: 1-267-295-7389
Data subjects can also contact the Banks Client service department or any of the Banks branches or
offices to obtain more information or to raise any concerns regarding the processing of their
personal data.

If you would like to know more about your rights as a data subject, regardless of whether it relates to
your account with Paxum Bank, a useful list of resources pertaining to data subject rights in various
countries can be found here(https://www.paxum.com/legal/country-list)

10. Changes to this Policy

10.1. The Bank may update this Privacy Policy from time to time. The Bank will notify data subjects
of any material changes to this Policy, such as changes to the purposes or categories of personal
data collected, or changes to the Bank's contact information. The Bank will obtain the necessary
consents from data subjects where required by applicable data protection laws.

The document has been accepted and

signed by: Luis Ernesto Gavino Escobar
Date/Time: 2025-01-01 at 11:18
IP Address: 47.60.32.32
User-Agent: Mozilla/5.0 (Linux; Android 14; SM-S711B Build/UP1A.231005.007; wv)
AppleWebKit/537.36 (KHTML, like Gecko) Version/4.0 Chrome/131.0.6778.135 Mobile
Safari/537.36

Paxum Bank Limited

Tel.: 1-866-347-4781
Fax: 1-267-295-7389