NOTICE OF PRIVACY POLICIES AND PRACTICES

At ABSEM Limited, and all of its subsidiaries and affiliates, (collectively referred to as “ABSEM”), we consider client relationships to be the foundation of our business and are committed to protecting the confidentiality of the personal information of our clients. We recognize the value of the trust that our clients and prospective clients (“client” or “clients”) place in us, and we are committed to continuing to earn that trust well into the future. If you have any questions regarding our policy or need additional copies of this notice please contact ABSEM at inquiry@absem.com or +44 (0) 20 3239 8601.

TYPES OF INFORMATION ABSEM GATHERS

The types of personally identifiable non-public information we collect and share depend on the product or service a client may have with us. This information may include, without limitation:

1. Name
2. Mailing address
3. Credit card or other payment/financial information
4. Business and/or home phone number
5. E-mail address
6. E-mail correspondence history

The personally identifiable non-public information of a client is collected in a number of ways, including: information on applications; forms; documents; transaction histories; and correspondence (electronic, written and telephonic) with clients. The ABSEM website(s) (“website”) may, from time to time, gather information about visitors and their potential needs through their submission of answers to surveys; information submitted in connection with becoming a registered user of the website; registration agreements; questionnaires; and data input to into various forms provided on the website. The information collected from the website includes, but is not limited to, name, mailing address and e-mail address. Additionally, ABSEM may collect data that is statistical in nature, which is not generally attributable to any specific client. By signing up for any one of ABSEM’s websites, you expressly allow ABSEM to share your information with its affiliates, and you consent to receive information from any/all of ABSEM’s affiliated Websites.

ABSEM may collect certain credit card and/or other entered financial institution information such as bank account numbers or PayPal email ID for Clients enrolled in ABSEM’s Automatic Subscription Renewal Program. ABSEM uses such information to bill subscription fees, as agreed to by the Client.

HOW ABSEM USES THE INFORMATION

ABSEM uses the information gathered to service client accounts and to provide clients with additional information about our products and services. ABSEM does not disclose any personally identifiable non-public information about current or former clients to any unaffiliated third party except as permitted by law, or at the specific request of the client. The information collected, as described above, may be shared with ABSEM, Limited subsidiary and affiliated companies for the purpose of enhancing and improving our client communications, services, products designed to meet the needs of our clients, and to bill subscription fees for Clients enrolled in ABSEM’s Automatic Subscription Renewal Program. We may, from time to time, disclose some or all of the above information to affiliated and unaffiliated companies that perform marketing and other services on behalf of ABSEM, or to other marketing services companies with whom we have joint marketing agreements. These parties that are not affiliated with ABSEM have agreed not to use this information for any other purpose.

POLICIES AND PRACTICES TO PROTECT CONFIDENTIAL INFORMATION

At ABSEM, we limit the availability of personally identifiable data about our clients only to employees who have a true business need for the information. Additionally, ABSEM maintains the highest standards of physical, electronic and procedural safeguards that comply with applicable local laws to protect the nonpublic personal information of our clients. Such safeguards include, but are not limited to, the use of firewalls for our web-based systems, encryption technologies, user authentication systems and mechanisms to ensure access control.

USER RIGHTS

On a regular basis, you will be given the opportunity to expressly agree in advance (“opt-in”) to our use of your personal data for marketing purposes, or ABSEM will provide you with an opportunity to refrain from allowing use of your personal data (“opt-out”) for marketing purposes. Additionally, you may instruct ABSEM not to process your personal data for marketing purposes by sending an email inquiry@absem.com at any time.

STORAGE OF PERSONAL DATA

All personal data collected by ABSEM may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for ABSEM, and/or contractors hired by ABSEM. By submitting your personal data to ABSEM, you agree to this transfer, storing and/or processing. ABSEM will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

SECURITY MEASURES TO PROTECT PERSONAL DATA

ABSEM operates commercially reasonable methods, including secure data networks protected by industry standard firewall and password protection, to keep personal data secure. ABSEM has reasonable security measures in place to attempt to protect against the loss, misuse or alteration of the personal data of users of our websites.

For Clients enrolled in ABSEM’s Automatic Subscription Renewal Program, ABSEM may collect certain credit card and/or other entered financial institution information such as bank account numbers or PayPal email ID, and to use that information to bill subscription fees. ABSEM uses secure Internet connections, using SSL (Secure Sockets Layer) encryption, to help protect Client financial data. Please note that with current technology, ABSEM cannot guarantee the security of Client data as it travels over the Internet.

SECURITY POLICY

ABSEM, Limited, and all of its subsidiaries and affiliates, (collectively referred to as “ABSEM”) is dedicated to providing a website that allows clients to access to information about our services. This Security Policy defines the standards implemented for the purposes of protecting the information that clients may provide while accessing the website. There are several terms clients should be familiar with as you read this policy:

1. Protected: The term “Protected” is used to describe a website (and/or an area of a website) for which a consent form must be completed before accessing. It is important to remember that a protected site is not necessarily a secure site.
2. Cookies: Cookies are minuscule data files that may be placed on the hard drive of a user upon visiting a website. These files enable the website to identify repeat visitors and may allow the website to customize the website depending on the preferences of the user. Cookies will not affect the performance of your computer.

Specific ABSEM standards with regard to personally identifiable non-public information are as follows:

Use of Cookies: ABSEM may, from time to time or on a continuous basis, use cookies when users enter our website. The use of cookies allows ABSEM to identify the user, observe which sections of the website are visited, and gain insight into the areas of the website are most frequently used. The allows ABSEM to tailor the website to individual needs of our clients. The cookies used in the protected areas of the site will reside on the user’s computer.

A temporary cookie may also be used on protected and unprotected sections of our site in order to relay information that is input on one page of the site by the shareholder to other areas that require the same information (e.g. different financial calculators). This relieves the user of having to input the same data on multiple pages. Temporary cookies will not be placed on the computer hard drive of a user, and will be used only during the current session; they are discarded once the user terminates their session.

Cookies are activated only during visits to ABSEM’s website and do not track activity once a user leaves the website.

Usage: We obtain statistical data relating to usage of all areas of the website; however, personal information is not gathered in these areas unless the user specifically inputs data that the user wishes ABSEM to have.