Privacy Policy

G2LINK (DBA TRUST EXCHANGE) RISK MANAGEMENT PLATFORM PRIVACY POLICY

G2Link recognizes that Your privacy and the protection of Your Personal Information is important to you, and therefore, has adoptedthis G2Link privacy policy. This G2Link privacy policy describes our privacy practices and how we treat the Personal Information that wecollect from You when You use products and services of G2Link, including any Personal Information we collected from You when Youcreated Your G2Link account. The G2Link privacy policy applies to all of the products, services, and websites offered by G2Link or ourrelated, affiliated and/or subsidiary companies (collectively, the “Products and Services.”)

For the purposes of this G2Link privacy policy, “Personal Information” is information that (i) You provide to G2Link and (ii) personallyidentifies You. Such information includes your name, email or other address, billing information or other data that can be reasonablylinked by G2Link to personally identify You. The Personal information may also include “Sensitive Personal Information.” The SensitivePersonal Information is Personal Information that (i) is related to confidential medical information, racial or ethnic origins, political orreligious beliefs and/or sexuality, and (ii) G2Link has actual knowledge thereof.

To protect Your privacy, G2Link does not associate Your website navigation activities to given Providers and/or conditions, and excludesfrom the Personal Information certain information that otherwise would be Personal Information. This “Excluded Information” isinformation that (i) is obtained via Your queries, searches or other interaction with G2Link, and (ii) relates to Providers and/orconditions. The Excluded Information, however, may be used for the purpose of generating “Aggregated Non-Personal Information,” asdescribed below.

Aggregated Non-Personal Information is information about some or all of the users of G2Link, but unlike the Personal Information, doesnot reflect or reference an individually identifiable user. The Aggregated Non-Personal Information may be formed from the Personal orExcluded Information, but any of the Personal or Excluded Information used to form the Aggregated Non-Personal Information has beenprocessed to no longer reflect or reference an individually identifiable user.

HOW WE OBTAIN THE PERSONAL INFORMATION

G2Link (or “we”) may obtain, collect, retain, store or otherwise maintain the Personal Information from the following sources. If youdecline to submit Personal Information, G2Link may not be able to or may choose not to provide to You some or all of our Products andServices.

INFORMATION YOU PROVIDE TO G2LINK

This information may include, for example, information provided to G2Link via a G2Link account assigned to You and other UserCommunications, as described in more detail below.

  • G2Link account – You need a G2Link account to access our Products and Services. When You sign up for a G2Link account, werequest from You Personal Information, such as your name, email or other address and an account password that is used to protectYour G2Link account from unauthorized access. G2Link stores, processes and maintains Your Personal Information and other datarelated to Your G2Link account to provide our Products and Services to You. For certain services, we may request credit card orother payment account information, which is maintained in encrypted form on secure servers.
  • Contact Information – G2Link may request or require contact and other personal identifying information, such as your name,address, phone number, and e-mail address. Your contact information may be used by G2Link to create a personalized experienceand for internal business purposes. We do not share your contact information with other third parties, without your consent, exceptto a court or governmental agency if required by law. In addition, we do not currently rent, license, or sell contact information toany third party.
  • Other Account Information – Some of the G2Link applications allows you to store information such as your financialprofessionals, financial facilities, vendors and customers, and custom financial information and related contact information. We donot share your account information with other third parties, without your consent, except to a court or governmental agency ifrequired by law. In addition, we do not currently rent, license, or sell contact information to any third party.

INFORMATION COLLECTED VIA INTERACTION WITH G2LINK

This information may include, for example server-log information, which is automatically recorded by our servers from an exchangebetween Your browser and our servers whenever You access, browse, or use G2Link .

  • Server log information – The server-log information may include information such as (i) account activity, including storage usage,number of log-ins, data displayed or selected, including user interface or “UI” elements, links, etc; and (ii) your web request, Internet Protocol address, browser type, browser language, the date and time of your request, date and time of access, one or morecookies that may uniquely identify your browser, cookie identification, referrer Uniform Resource Locator, etc. Please note thefollowing with respect tocookies.
  • Cookies – When You visit G2Link, we send to Your computer one or more cookies (i.e. a small file containing a string ofcharacters) that uniquely identifies your browser. We use cookies to improve the quality of our Products and Services by storing userpreferences and tracking. Most browsers are initially set up to accept cookies, but You can reset your browser to refuse all cookies orto indicate when a cookie is being sent. Please note, however, some features of the Products and Services of G2Link may notfunction properly, if at all, if your cookies are disabled.

INFORMATION G2LINK PROVIDES TO YOU

This information may include, for example, information provided to You from G2Link via G2Link-initiated communications. TheseG2Link -initiated communications, which may be in the form of paper mail, email or other electronic communications, arecommunications sent to You by G2Link, and can include communications that contain information related to Your G2Link account.

HOW WE USE THE PERSONAL INFORMATION

G2Link only uses the Personal Information for the purposes described in this G2Link privacy policy. In addition to any of the purposesnoted in other sections of this G2Link privacy policy, G2Link only uses the Personal Information for:

  • providing the Products and Services to users, including the processing, formatting and displaying of the Personal information andcustomized content;
  • auditing, research and analysis in order to maintain, protect and improve our services;
  • ensuring the technical functioning of our network, including creating and maintaining back ups or other archival copies of thePersonal information and other related data; and/or 
  • developing new services.

In addition to using the personal information that we track for internal purposes in the manner described here, this information mayalso, on an aggregate basis, be shared with and used by third parties with which we have contracted (e.g., our third-party contentproviders and licensees of G2Link’s services). Furthermore, in addition to G2Link providing its own advertising, G2Link uses third-partyadvertising companies and networks to serve ads when you visit our site. These companies and networks include, among others, thirdparty ad servers, ad agencies, ad technology vendors, and research firms.

These companies and networks may use information (not including your name, address, email address, or telephone number) about yourvisits to our site in order to provide advertisements about goods and services of interest to you. In the course of serving advertisements tothe Sites, our ad networks may place or recognize a unique “cookie” on your browser or use a “web beacon.” An example of such adnetwork is Google, Inc. If you would like more information about this practice and to know your choices about not having thisinformation used by Google, Click here . If you would like more information aboutnot having this information used by other companies, please Click here . G2Link may allowcertain G2Link affiliates to include web beacons within pages served by G2Link. These affiliates aggregate information about ouradvertising and provide auditing, research and reporting for our advertisers.(https://www.google.com/policies/technologies/ads/) (http://www.networkadvertising.org/choices/) 

Please note that ad networks’ use of cookies or web beacons, and that of any other third-party that has a link available on any Site, is subject totheir own privacy policies and not this privacy policy.

If we propose to use the Personal Information for any purposes other than those described in this section or any other section of thisG2Link privacy policy and/or in any specific notice to You regarding the same, we will ask for your consent prior to such use and offeryou an effective way to opt out of the use of Personal Information for those other purposes. As above, if you opt out or otherwise declineto submit Personal Information, G2Link may not be able to provide to You our Products and Services.

LINKS AND CO-BRANDED SITES

This policy only addresses this Site and related Services. Other websites, such as those to which we link or with which we co-brand, mayhave their own policies. These other sites to which we link or with which we co-brand might independently collect data, solicit personalinformation, or send their own cookies to you. We are not responsible for any use of information when you use such third party sites andservices. Additionally, in many cases, co-branded services that are jointly provided by us and selected companies will contain the Sites’branding, but might not be hosted by us. In such cases, you should follow the privacy and terms of service link on such site to determinewhich company’s privacy policy protects the information you enter on such site. Even if the page is governed by a separate privacy policy,we might be entitled to receive information about what you do when using that service. We encourage you to read the privacy policiesand terms of service of these other companies and to contact these companies directly if you have any questions about their use of thisinformation.

INFORMATION SHARING AND ONWARD TRANSFER

Unless otherwise agreed to in writing, we reserve the right to sell, rent or otherwise share some or all of Your Personal Information withother companies or individuals outside of G2Link when:

  • we have your consent (which, except for Sensitive Personal Information, shall be deemed given unless You have opted out; forSensitive Personal Information, we require opt-in consent); and/or

If G2Link becomes involved in a merger, acquisition, or any form of sale of all of its assets, we will provide notice before PersonalInformation is transferred and becomes subject to a different privacy policy.

We may share with others certain pieces of Aggregated Non-Personal Information. Such information does not identify you individually.

Please contact us at the address below for any additional questions about the management or use of Personal Information.

INFORMATION SECURITY

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction ofdata. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physicalsecurity measures to guard against unauthorized access to systems where we store personal data.

We restrict access to Personal Information to employees, contractors and agents of G2Link who need to know that the PersonalInformation to operate, develop and/or improve our services. These individuals are bound by confidentiality obligations and may besubject to discipline, including termination, if they fail to meet these obligations.

DATA INTEGRITY

G2Link processes the Personal Information only for the purposes for which it was collected and in accordance with this G2Link privacypolicy. We periodically review our data collection, storage and processing practices to ensure that we collect, store and process thePersonal Information for providing and/or improve our Products and Services. We also take reasonable steps to ensure that the PersonalInformation we process is accurate, complete, and current, but we depend on our You and our other users to update or correct theirPersonal Information whenever necessary.

ACCESSING AND UPDATING PERSONAL INFORMATION

Except as required by the User Agreement, You may change the settings of Your G2Link account via the “settings” section of suchaccount. You may organize or delete certain information through such settings or, alternately, terminate Your G2Link account. Suchdeletions or terminations will take immediate effect. Residual copies of the deleted information and/or terminated G2Link account maytake up to 60 days to be deleted from active servers and may remain in perpetuity in backup systems.

When you use our Products and Services, we make good faith efforts to provide you with access to your Personal Information and eitherto correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or forlegitimate business purposes. Where applicable, we ask individual users to identify themselves and the information requested to beaccessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive orsystematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance,requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case, where we provideinformation access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Someof our Products and Services have different procedures to access, correct or delete Your Personal Information. Please contact us for thedetails for these procedures

ENFORCEMENT

G2Link regularly reviews its compliance with this G2Link privacy policy. Please feel free to direct any questions or concerns regardingthis G2Link privacy policy or our treatment of Personal Information by contacting us the address below. When we receive formal writtencomplaints at this address, our policy is to contact the complaining user regarding his or her concerns. We will cooperate with theappropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of PersonalInformation that cannot be resolved between an individual and G2Link.

CHANGES TO THIS POLICY

Please note that this G2Link privacy policy may change from time to time. We will not reduce your rights under this G2Link privacypolicy without your consent, and we expect most such changes will be minor. Regardless, we will post any changes on this page. If youhave any additional questions or concerns about this Policy, please feel free to contact us at:

G2Link
Attn: Legal Department

MORE INFORMATION

G2Link adheres to the US Safe Harbor privacy principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access andEnforcement. For more information about the Safe Harbor framework, see the Department of Commerce’s web site.