Privacy Policy

Customer and Website Privacy Policy
Regarding Customer Personal Information and Website Regulations

At Shabacare we are committed to protecting customer privacy and safeguarding personal information in every transaction, at every level of our organization.
This privacy policy (“Policy”) is for Shabacare, N.A. and International transactions, other “Shabacare” named entities, and their affiliated entities (collectively “Shabacare” “we” or “us”), and applies to personal information (“Personal Information”) we collect on our website about individuals who are principals or representatives of our customers.
We do not use Personal Information for purposes other than as outlined in this Policy unless we have consent or are otherwise required or permitted to do so.

1. What Information We Collect
We will only collect the Personal Information we need for the purposes described in this Policy. We may collect Personal Information about consumers and representatives or principals of our Customers such as:
• Information establishing individual identity, such as name, other governmental identification information, home address and telephone number, date of birth, and country of domicile.
• Information about customer transactions or experiences with us and other Shabacare affiliated companies

2. How We Use Personal Information
We may use the Personal Information we collect for the following purposes:
• To provide the services requested by individual consumers or business Customers
• To protect customer accounts from unauthorized access or identity theft
• To fulfill other legal and regulatory obligations pertaining to foreign exchange and Shabacare
• To promote or market Shabacare or third-party products and services
• To manage our risks and operations
• For other legitimate purposes required or permitted by applicable law

3. Consent and Choices
In most cases we ask for permission to collect, use and disclose Personal Information in connection with the purposes described in this notice before we collect Personal Information. In some cases, we may assume consent when individuals provide their Personal Information directly to us in connection with a transaction or service for purposes of completing that transaction or providing that service. In limited situations, we may collect and use Personal Information without consent. These include when we are legally required to disclose information, for our protection (such as collection and fraud prevention) and to comply with law, regulations or regulatory authority. An individual may withdraw consent, subject to our right to continue to use Personal Information to fulfill our contracts with the customer, collect debts or as otherwise permitted or required by law.

Choices for Marketing Communications
You are in control of how we may contact you for marketing products and services, and we provide the opportunity to tell us not to use Personal information for such purposes. If you do not want to receive marketing and sales materials by direct mail, telephone, facsimile or email, please submit your request to the Privacy Office below.. We will comply with your request within a reasonable period of time after receiving it as well as with applicable law.

3. Legal Requirements:
Subject to applicable law, we may disclose Personal Information if required or permitted by law or regulation or in the good faith belief that such action is necessary to:

• Comply with a legal obligation or in response to a request from public authorities or self-regulatory bodies to which we are subject, wherever we may do business
• Protect and defend the rights or property of Shabacare
• Detect, prevent or report to law enforcement agencies fraud or other illegal activity
• Verify identity and conduct required due diligence
• Act in urgent circumstances to protect the personal safety of clients and workers/employees of Shabacare or the public
• As permitted or required by law
• Protect against any legal liability

We have a Privacy Office which oversees our compliance with this policy and law. Please direct all requests relating to access, correction, marketing opt outs, complaints, any questions regarding this Policy, or for a copy of our Policy for the Protection of Personal

Information to:
Privacy Office
Attn: Privacy Officer
Your comments are valuable to us and we assure you that we will do our best to address them.

4. Modifications

This Policy may be modified as a result of amendments to the law or regulations or due to other reasons. In such case, an amended Policy will be posted on our website. The page providing the Policy shall contain a date as to when the Policy was last updated. We will not materially change the purposes for which we use or disclose your Personal Information without first obtaining your consent. This policy is available in English and French upon request.

Last updated: October 2018
© 2018 Shabacare. All rights reserved