PRIVACY POLICY

1. Identity and Address

Inteligo Bank Ltd. ("Inteligo Bank" or the "Bank") is an incorporated and existing bank under the laws of the Commonwealth of The Bahamas. Its main office is located at Balmoral Corporate Centre, Ground Floor, Unit B, Nassau, Bahamas. It also has a branch office in Panama at Tower Financial Center, 50th Street and Elvira Mendez Street, 48th Floor, Panama, Republic of Panama.

2. Necessary Purposes

Your personal data will be used for the following necessary purposes related to the services if you wish to sign up or open an account with Inteligo Bank:

• To verify and validate user identity (client or potential client).
• To formalize and manage the products and/or services contracted with the Bank. This includes financial and/or risk assessments, data processing and updating, contractual formalizations, debt collection, financial operations management and correspondence forwarding.
• To send account statements and information about the products and/or services contracted with the Bank.
• To handle and manage claims, complaints, inquiries and requests made through the channels authorized by the Bank.
• To prevent or detect fraud or criminal activities or to manage and resolve any actual or potential loss in connection with a crime or fraud.
• To share personal data with supplier companies to fulfill the services provided by the Bank.
• To host, store and process client information to specialized companies, national or international, that provide services on cloud-based infrastructure.
• Manage compliance with legal obligations.

3. Optional Purposes

As described in the Bank's Terms and Conditions, the Bank may use its clients’ personal data for the purposes of direct marketing of its existing or future products or services, promotional offers or invitations to events. Communications sent by the Bank within the scope of its advisory services to its clients such as marketing information, securities issuer results, investment opportunities or regulatory notices are not considered direct marketing.

By opening an account with the Bank, the client consents to the use of his/her personal data for the optional purposes described above. However, if the client does not wish to be contacted for direct marketing purposes, the client may write to:

inteligomail@inteligogroup.com
Balmoral Corporate Centre, Ground Floor Unit B, PO Box N-3732 Nassau, The Bahamas

4. Mandatory Personal Data

In order to carry out the necessary purposes described in this Privacy Policy and depending on the type of service or product to be contracted, it is mandatory that you provide us with the following personal data:

• Identifying data: Names, surnames, ID/Passport/RUC(Taxpayer Identification Number), home address, telephone, email, voice, signature, electronic signature.
• Personal characteristics data: Marital status, date of birth, nationality, sex, age, profession.
• Economic-financial data: Bank data, credits, loans, guarantees, credit history, tax information, insurance, credit cards, assets, mortgages, benefits received from social programs, debts.
• Social data: housing characteristics.
• Sensitive data: Financial income and biometric data.

We use sensitive data to fulfill the purposes of the contractual relationship, such as validation of identity and evaluation of the client's credit risks.

5. Consequence of providing personal data or your refusal to do

Should the mandatory personal data not be submitted for the necessary purposes, INTELIGO BANK will not be able to provide you with the service or product to be contracted.

6. Necessary Recipients

Your data may be processed by third parties - at national or international level - on behalf of INTELIGO BANK in order to fulfill the necessary purposes described above:

• National Authorities and Central Credit Bureaus
• Hosting Providers
• Courier service providers
• Contact center service providers
• Collection service providers
• Consulting Service Providers
• Technology providers
• Documentary or securities custody service providers

7. Storage Period

INTELIGO BANK is obliged to keep the documents and information generated by the contracting of our services and/or products for a period of no less than ten (10) years after the termination of the contractual relationship; or as long as we have your consent for optional treatments.

8. Security Mechanisms

At INTELIGO BANK, we have the following technologies to offer a more secure service:

• Firewalls: our network is protected by firewalls that prevent unauthorized users from accessing our network.
• Antivirus: our servers have the latest antivirus updates and technologies.
• We have authentication mechanisms such as the use of security questions and SMS tokens for secure electronic links.
• Updates (patches): we have a patch update program that continuously checks for new vulnerabilities applicable to our environment.

9. Right to Complain

You may exercise your rights of access, rectification, cancellation and objection of your personal data; as well as revoke your consent for the optional purposes by submitting your requests at any of the INTELIGO BANK offices indicated at the top of this Policy, as well as in the mailbox: opdp@inteligogroup.com of the Personal Data Protection Officer.

If you feel that you have not been assisted in exercising your rights, you may file a complaint with the Central Bank of The Bahamas:

Central Bank of The Bahamas
P.O. Box N-4868
Nassau, N.P, Bahamas

INTELIGO BANK reserves the right to amend, update or supplement this Privacy Policy at any time. Any changes or amendments to this Privacy Policy may be made at any time and will be disclosed through our authorized channels.