Document effective 15th March, 2021

Version 2.2

Zenus Bank is committed to protecting the privacy of all personal information that we obtain from you. Our Privacy Policy (the “Policy”) explains how Zenus Bank International Inc. (“Zenus”, “we” or “us”) collect, use, disclose and protect your information.

This Policy applies to information we collect when you use our website, online banking or mobile applications, among others (collectively, “Services”) or otherwise interact with us as described below.

Zenus is based in the Commonwealth of Puerto Rico and the information we collect is governed by United States and Puerto Rico law. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the US and other countries. Zenus Services include the use of Zenus websites, Zenus Apps and online banking.

If you have signed up for, applied for, have or previously had one of our consumer Products, the Zenus Privacy Notice will apply to you. These provide more information about how we collect and share your personal information and outline certain choices you may have. If there is a conflict between this Online Privacy Notice and any privacy notice, disclosure, policies or terms relating to any Product, the privacy notice, disclosure, policies or terms relating to the Product will govern.

Zenus services are not intended for children under 13. We do not to knowingly market or solicit information to or from children under the age of 13. In the event that Zenus desires in the future to market or solicit such information, Zenus shall develop and implement appropriate policies and procedures prior to such activities.

We collect your personal information in order to provide you with our products and services and to open and manage your account. By collecting your information, Zenus is able to monitor and improve the services we offer to all existing and potential clients.

We may use your information as follows, to:

Provide, maintain and improve our Services;

• Provide and deliver the products and services you request, process transactions and send you related information, including confirmations;
• Verify your identity and prevent fraud;
• Send you technical notices, updates, security alerts and support and administrative messages;
• Respond to your comments, questions and requests and provide client services;
• Communicate with you about products, services, offers, promotions, rewards, and events offered by Zenus and others, and provide news and information we think will be of interest to you;
• Monitor and analyze trends, usage and activities in connection with our Services;
• Personalize and improve the Services and advertisements, content or features presented both on and beyond Zenus Services;
• Process and deliver contest or promotion entries and rewards;
• Link or combine with information we get from others to help understand your needs and provide you with better service, and;
• Carry out any other purpose for which the information was collected. Where appropriate, we will limit sharing of your information in accordance with the choices you have provided us in response to our Privacy Notice.

3.1. Information you provide to us We collect the personal information you provide when you apply for a Zenus account or communicate with us through our channels or social media. The types of information we may collect include your name, address, phone number, email address, date of birth, bank account information, preferences, username, and password.

For your additional security, we will ask you to provide bio-metric data in the form of a selfie photograph and a voice statement during account opening. This may be used by Zenus to identify and verify you as the account owner or to authorize account activity.

3.2. Information about your transactions with us

As you use your Zenus account to perform financial transactions, we collect information in connection with each transaction, including transaction time, amount and merchant or Ultimate Beneficial Owner ((“UBO)”) details. We may also collect photos, memos or other information that you attach to your transactions.

3.3. Information from other sources

When you apply for a Zenus account, we may collect information, including non-public personal data, about you from non-affiliated third-party service providers in order to verify your identity, for fraud prevention, including your prior addresses and names, and to verify your eligibility for products and services.

3.4. Information we collect automatically

When you access or use our Services, we will automatically collect specific information about you:

• Log Information: We log information about your use of our Services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Services
• Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers and mobile network information. We may also collect other device identification information for the purposes of detecting and preventing fraud, including battery life, whether the device is moving and its camera capabilities.
• Location Information: We may collect your precise location information from your mobile device in accordance with the permission process set by your mobile device. Additionally, we may also derive your approximate location from your IP address. Also, we have incorporated Google Maps into our Services, and you may consent to the collection of location information by Google Maps in connection with your use of this maps service. Any information collected via your use of Google Maps will be transmitted directly to Google and is not collected by us. Please refer to Google’s privacy policy for details about their collection, use and sharing of this information. For information about how to disable the collection of location information from your device, please see “Your Choices” below.
• Stored information: We may access information you have stored on your mobile device via our mobile app in accordance with the permission process set by your mobile device. For example, with your permission, we may access contacts from your device address book or photos from your device photo gallery.
• Information collected by cookies and other tracking technologies: We use various technologies to collect information on our Services and these may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve our Services and your experience. For more information about cookies, and how to disable them, please see our Cookie Policy.

We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.

To provide the Services, we may disclose any information we collect about current and former clients, including non-public personal information, to affiliates and non-affiliated third parties as follows:

• With financial service providers, including the financial institutions identified in your cardholder bank agreement that provide banking services in connection with your Zenus account;
• Third Party Service Providers
  • With non-financial companies, such as email service providers that perform marketing services on our behalf, and fraud prevention service providers that use the information to provide services to Zenus and other companies.
  • With a non-affiliated third-party to access and transmit your personal and financial information from a relevant financial institution. You grant the third-party the right, power, and authority to access and transmit this information according to terms of their privacy policy;
  • With advertising agencies and technology providers to improve the relevance of advertising you receive from us.
• Other Zenus Bank Members:
  • Zen Transfers are an easy way to make transfers or payments between Zenus Bank members using their Zenus Bank accounts.
  • Other Zenus member will be able to add you as a Zen Transfer beneficiary using your account number or the mobile phone number registered to your account. When a Zenus member adds you as a beneficiary using your mobile phone number, we will share your full name with this member so that they can validate your identity.
• With other non-affiliated companies for our everyday business purposes, such as to process transactions, maintain accounts, respond to court orders and legal investigations or report to credit bureaus. For example, in connection with our everyday business purposes, we may share information about you as follows:
  • In response to any request for information, writ, subpoena or similar petition, if we are required by, or we believe disclosure is in accordance with, any applicable law, regulation or legal process;
  • With relevant law enforcement officials or other third parties, such as investigators or auditors, if we believe it is appropriate to investigate fraud;
  • If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of Zenus or others;
  • In connection with, or during negotiations of, any merger, reorganization, sale of Zenus’ assets, financing or acquisition of all or a portion of our business to another company, and;
  • With your consent or at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide such information.

We may also share aggregated or de-identified Information, which cannot reasonably be used to identify you. For example, we may share transaction zip codes and merchant names with third parties to improve our accuracy in geo- locating transactions and to improve the clarity of transaction descriptions.

Regarding the personal information we hold about you, you have:

• The right to be informed about processing of your personal data;
• The right to have your personal data corrected if it’s inaccurate and to have incomplete personal data completed;
• The right to object to processing of your personal data;
• The right to restrict processing of your personal data;
• The right to have your personal data erased (the "right to be forgotten");
• The right to request access to a copy of your personal data and information about how we process it. Please make all requests for access in writing (see how to contact us for details) and provide us with evidence of your identity;
• The right to move, copy or transfer your personal data (“data portability”); and
• Rights in relation to automated decision making including profiling.
• The right to limit (opt-out) some — but not all — sharing of your information.

Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request. We will stop processing your personal data unless the processing is for the establishment, exercise or defense of legal claims or we have a legitimate business purpose or legal grounds for the processing.

We aim to give you as much control over the use of your data, you can choose

6.1. Account information

You may edit your account profile information by logging into your account via our services. If you wish to delete or deactivate your online account, please contact us, but note that we may retain certain information as required by law or for legitimate business purposes.

6.2. Promotional communications

By default, you will have to opt in to receiving marketing or promotional emails and text messages from Zenus. This is done during your account application but can be changed from within our mobile app or online banking settings. Equally you can unsubscribe from marketing emails by following the instructions within those messages. Please note that if you opt out, we may still send you transactional or relationship messages, such as those about your account or our ongoing business relations.

6.3. Location information

If you initially consent to the collection of precise location information by Zenus or Google Maps from within our mobile application and online banking, you may be able to subsequently stop this collection through your device operating system settings. If this option is not available to you, you may also disable collection of this location information by following the standard uninstall process to remove our mobile application from your device. However, please know it is not possible to use our services without sharing your location.

6.4. Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our services. Please read our Cookie Policy for more information.

6.5. Do not Track

We allow browser configuration known as (“Do Not Track”). However, the use of a Do Not Track status may alter the available services with certain browsers, when these tracking functionalities are used to provide services. We do not alter the information our applications attempt to collect based on your Do Not Track configuration.

Zenus takes all reasonable measures to ensure your personal data is handled securely and in line with this privacy policy and data protection laws. We’ll do our upmost to protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

We limit employee access to client information, only employees that have a business reason to review your information may. Equally, we employ multiple internal policies designed to protect the confidentiality and security of your personal information, including a privacy protection policy for social security numbers.

The technology we use along with our security practices and procedures are all designed to protect the confidentiality and security of your information. Please read our Security Policy for more information on this.

Please note that information you send to us electronically may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us.

7.1. Where will my data be stored?

Please be aware that you are sending information (including Personal Data) to the United States where our servers are located. That information may be transferred within the United States and back out of the United States to another countries.

Data is collected, handled and stored in accordance with prevailing EU and UK laws.

If you are a California resident we offer you the rights afforded by the California Consumer Privacy Act (CCPA). These include the right to:

• Request the specific pieces of personal information we collected about you; the categories of personal information we collected; the categories of sources used to collect the personal information; the business or commercial purposes for collecting your personal information; and the categories of third parties with whom we share your personal information each as it pertains to our activities in the preceding twelve (12) months.
• Request, on legitimate grounds, deletion of your personal information that we collected;
• Opt-out of disclosures of your personal information to third parties under certain circumstances; and
• Not to be discriminated against for exercising any of these rights.
  
  You should be aware these rights do not apply to:
• Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act and its implementing regulations, the California Financial Information Privacy Act, and the Driver’s Privacy Protection Act of 1994; or
• Other information subject to a CCPA exception.
• If you would like to discuss or exercise such rights, please refer to the “How to contact” section below. As part of submitting a request, we will ask for your name, email address, phone number, date of birth, and mailing address

From time to time, we may change this Privacy Policy. If we make changes, we will update the version and effective date at the top of this policy, and in some cases, we may provide you with additional notice (such as by adding a statement to our website, online banking or mobile applications or by emailing you).

Any changes to this Policy will become effective when we post the revised Policy on this page. Your use of Services following these changes means that you accept the revised Policy.

We encourage you to review the Policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy.

If you have any questions about this policy, would like to action a right or make a complaint please contact Client Services.

Or write to us at:

Zenus Bank International, Inc, City Towers, 19th Floor, 252 Ponce de Leon, San Juan, PR, 00918, USA.