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PRIVACY SHIELD PRIVACY POLICY

Revision 2.2 (9/26/2017)

At Pandesa Corporation, doing business as ShareVault ("ShareVault"), we strive to protect the privacy of your information. We affirm commitment to comply with the Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, storage, use, transfer and other processing of Consumer Personal Data transferred from the European Economic Area (“EEA”) or Switzerland to the United States. ShareVault is certified by the U.S. Department of Commerce that it adheres to the standards of the U.S.-EU Privacy Shield Framework and the U.S.-Swiss Privacy Shield Framework to protect your electronic information within ShareVault. This policy outlines 1) our practices for implementing the Privacy Shield privacy principles for covered Personal Data, 2) the choices you can make about the way your information is collected and used within this website and the software solutions provided herein, and 3) measures available to resolve complaints about our collection or use of your personal information. This policy is published on the ShareVault website and a link to this policy is displayed on every page within the application where you information may be collected or available to you.

To access the published ShareVault Privacy Shield Privacy Policy, visit https://www.sharevault.com/privacy-shield.

To learn more about the Privacy Shield program, visit https://www.privacyshield.gov/.

At ShareVault, we protect the privacy of your information and abide by the Privacy Shield privacy principles as set forth by the U.S. Department of Commerce regarding the collection, storage, use, transfer and other processing of Consumer Personal Data transferred from the European Economic Area (“EEA”) or Switzerland to the United States. For further information, refer to the ShareVault Privacy Shield Policy and our listing on the U.S. Department of Commerce | EU-U.S. Privacy Shield list.

What We Collect, How We Use It and Who We Share With

ShareVault uses any collected information to inform our prospects and customers about our solutions, to provide services requested by our customers, and to support our customers as they utilize our services and to safeguard their security. For example, ShareVault may respond to you, if you fill out a "Contact" form on our web site, with information about our services and provide secure access to our services. ShareVault may also use data about ShareVault customers for its own marketing purposes, in order to provide information about promotions or events. ShareVault uses credit card information solely to evaluate the financial qualification of prospective customers and to collect payment for services. ShareVault uses web site navigational information to operate and secure our web sites and to provide personalized information about the company.

ShareVault will not share, sell or distribute your personal data to unrelated third parties without your consent. All personal data may be disclosed only to third parties who directly support the use cases for personal data as summarized above and in more detail in the ShareVault Privacy Policy, who subscribe to the Privacy Shield Principles, who are subject to the Data Protection Directive, and who enter into a written agreement to provide the equivalent level of privacy protection. We acknowledge our liability for such data transfers to third parties.

The full extent of personal data collected, the purpose for which the data is used, and the limits for disclosure of this information to third parties is further detailed within the ShareVault Privacy Policy.

No sensitive data as defined by Privacy Shield Principles is collected or shared otherwise.

To access the published ShareVault Privacy Policy, visit https://www.sharevault.com/privacy-policy.

Your Rights

By using our websites and/or services, you signify your agreement to the privacy polices described above. If you have any questions about this privacy statement, please email us at privacy@sharevault.com.

Correcting and Updating Your Information

Users of ShareVault services may access their personal data to update or change their profile information by logging into the service, selecting the "Preferences" tab, and removing or updating information using the online interface. Organizations seeking to update information should contact ShareVault Support by submitting a web site "Contact" form, sending an email to support@sharevault.net, or calling (408) 717-4955, ext. 2. To discontinue your account and to have your information maintained in a ShareVault archive or returned to you please email support@sharevault.net. Should you decline to receive mail or email from ShareVault that does not relate directly to your access to or use of ShareVault permission-based services, please visit our unsubscribe page and fill out the form.

Security and Dispute Resolution

To prevent unauthorized access, maintain data integrity, and ensure the correct use of information, ShareVault has instituted a wide array of policies, procedures, and mechanisms to securely protect the information we collect online. This includes the use of personal information to confirm the identity of users who use ShareVault services. To provide trusted user authentication, sensitive personal information is requested and used internally within the application and is likewise secured with utmost care and diligence.

Additional details regarding security are described in the ShareVault Security Policy, published here: https://www.sharevault.com/security-policy.

In Compliance with the Privacy Shield Principles, ShareVault is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). ShareVault may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

ShareVault takes information security and privacy seriously. Should you have a question, concern, or complaint about how ShareVault collects or uses personal information, please first submit any such complaints directly to privacy@sharevault.com. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at JAMS.

JAMS Privacy Shield Compliance Enforcement

JAMS is the independent organization responsible for reviewing and resolving complaints about our Privacy Shield compliance. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact JAMS at https://www.jamsadr.com/eu-us-privacy-shield. The services of JAMS are provided at no cost to you.

Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Under the terms which Privacy Shield organizations are obligated to arbitrate claims, pursuant to the Recourse, Enforcement and Liability Principle. The binding arbitration option described therein applies to certain “residual” claims as to data covered by the EU-U.S. Privacy Shield. The purpose of this option is to provide a prompt, independent, and fair mechanism, at the option of individuals, for resolution of claimed violations of the Principles not resolved by any of the other Privacy Shield mechanisms, if any.