Privacy Policy

AB Handshake Corporation works to protect the privacy of personal data entrusted to us.
Our mission is to protect privacy rights in the digital era.

Our strategic objectives are to:

• enhance public trust and confidence in our data usage;
• deliver exceptional telecommunication services with high standards of information security and privacy;
• stay current with evolving technology.

We strive to earn the trust of our data subjects daily by adhering to six core privacy principles:

1. lawfulness, fairness, and transparency;
2. purpose limitation;
3. data minimization;
4. accuracy;
5. storage limitation;
6. integrity and confidentiality.

This page informs you of our processing of your personal data when you:

1. visit our site,
2. subscribe to our marketing material (newsletters and special offers),
3. contact with us about employment,
4. interact with our social media pages our social media pages, interact with our company and our specialists,

and the choices you have associated with that data.

In this case, we act as the controller of your data.

This policy also describes how we process your data as a processor when providing anti-fraud services to other telecommunications companies.

We want to be as secure as possible for your personal data, so your privacy is one of the priorities for us.

Please carefully read this document.

Some terms that can be seen in this document:

Automated decision-making is a decision that our system makes automatically due to its specific algorithm and without human participation.

Cookies are small pieces of data stored on your device.

Personal data means any information that is linked or reasonably linkable to an identified or identifiable individual, and does not include de-identified data or publicly available information.

Profiling means any form of automated processing performed on Personal data to evaluate, analyze, or predict personal aspects related to an identified or identifiable individual’s economic situation, health, demographic characteristics, personal preferences, interests, reliability, behavior, location, or movements.

About us

AB Handshake Corporation is responsible for processing your personal data.

If you have any questions about this policy or our processing of your personal data, we hope that you contact us, and we will be able to resolve your issue. You can contact us either by:

1. email: privacy@abhandshake.com
2. postal address: 66 West Flagler Street, Suite 900 — #2329, Miami, FL 33130, USA.

We will respond to your requests via the email address provided or in any other form of your choosing.

In cases where we process Personal data to provide services to our client and according to their instructions, we act as the Processor, and in extreme cases, we act as the Controller.

Your rights and how to exercise them

Your personal data is subject to several rights:

1. access your data;
2. make amendments and additions;
3. erase your personal data;
4. object to particular data processing;
5. receive your data from us in electronic format to transfer it to another entity;
6. not to be subjected to automated decision-making (i.e., a decision that our system makes automatically due to its specific algorithm and without human participation).

In any case, you can always ask us how we process your data and how you can exercise your rights.

Rights description:

1. The right to access:
   Confirm whether your personal data is processed, access such personal data, and obtain a list of the categories of third parties to which we have disclosed your personal data.
2. Right to rectification:
   Correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing.
3. The right to erasure (the "right to be forgotten"):
   Delete personal data.
4. The right to data portability:
   Obtain a copy of your personal data processed by us, as the controller, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means, provided we shall not be required to reveal any trade secret.
5. The right to object to processing:
   Opt out of the processing of your personal data for purposes of targeted advertising or the sale of personal data.
6. The right not to be subjected to automated decision-making:
   Opt out of the processing of your personal data for purposes of profiling in furtherance of solely automated decisions that produce legal or similarly significant effects concerning you.

Requests and complaints

You can send us a request if you have any questions about your privacy rights or how to exercise them or complaint.

To submit a request or complaint, you can use our form on the website or send us an email to the mailbox privacy@abhandshake.com.

We aim to respond to your request as soon as possible, and always within 30 days after receipt of the request. Some requests can take up to an additional 30 days when reasonably necessary, depending on the complexity and number of the consumer’s requests. We will inform you if an extension is necessary and explain the reasons for the delay.

If your request or complaint is unclear, we may contact you to clarify its content. Requests may also be refused if they are clearly unfounded or excessive (repetitive).

If there are doubts whether you have really contacted us (and not someone impersonating you), we have the right to request confirmation of your identity (e.g., by confirming some data known to both you and us or by providing a copy of your identity card).

You may also contact us at:

AB Handshake Corporation

66 West Flagler Street,
Suite 900 — #2329,
Miami, FL, USA, 33130

The sources of personal data

Where do we get your data from?

• we receive it from you (e.g. when you interact with our site);
• we collect it automatically from your device;
• we receive it from other services and persons;
• we assign or generate it ourselves;
• from another company that transfers them to us to receive antifraud services.

In the annex, you will find the categories of personal data that we collect, along with a list of personal data that may be affected for each category.

Who we can share your data with

We may share your personal information with our service providers, who handle data processing for us. Additionally, we might share it with public, government, judicial, and law enforcement agencies, provided we are legally allowed to do so.

We can also share your information with trusted third parties, such as:

• external and internal lawyers and/or specialist advisors (to protect our legitimate interests);
• public and governmental agencies (to perform our legal duties and obligations);
• the police or other government agencies (in the event of a crime or conducting investigations).

Retention of personal data

The period during which we store your data may be determined by:

• the period necessary to provide you with the services or information requested;
• our legitimate business interests and the need to protect our rights and interests;
• our partner (when we act as Processor).

We store information for as long as necessary to provide you with services or information (e.g., sending newsletters or providing requested information).

Additionally, we may store some personal data for as long as needed to support or protect our legitimate and significant business goals and interests (e.g., for analytical purposes).

We will store the required personal data only if necessary for:

• resolving claims or disputes;
• ensuring our security;
• preventing fraud and money laundering.

As a rule, this period does not exceed 1 year and applies only to some of your data.

How we provide the security

We prioritize the security of your data. Thus, we employ standard protection measures and ensure that our partners also maintain an appropriate level of security.

Our aim is to safeguard user data by implementing all necessary and appropriate measures to prevent loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. We uphold a robust information security program designed to secure your personal data through physical, technical, and administrative controls.

To protect your personal data, we:

• select trustworthy partners who meet personal data protection standards;
• have established a comprehensive set of security policies covering a variety of topics;
• restrict and differentiate access levels to your personal data for our employees and third parties, monitoring who accesses and uses it;
• limit data access to authorized employees who need it to perform their duties;
• encrypt data.

If you have any questions, please contact us at privacy@abhandshake.com.

Personal data breach

In the event of a personal data breach, we are committed to mitigating the impact and addressing any consequences for you. It is important to understand that no security system is infallible; therefore, we cannot guarantee complete protection against unauthorized access or breaches by third parties. Should such incidents occur, we will implement all reasonable measures to rectify the situation and mitigate any resulting damage.

If required, we will inform you or inform the controller (who will then inform you) of any violations concerning your personal data and report the breach to the appropriate regulatory authority in accordance with legal requirements.

Changes to the Privacy Policy

This Policy may change periodically. We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments.

Periodically reviewing our website is a good idea to stay informed about our privacy policies relating to your personal data.

However, you can always review the latest version of our Privacy Policy and all previous versions on our website.

It is our policy to post any changes we make to our Privacy Policy on this page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our website and this Privacy Policy to check for any changes.

The invalidation of certain provisions of the Privacy Policy for any reason does not entail the invalidity of the Privacy Policy as a whole or its other provisions.

EU-U.S. Data Privacy Framework Compliance

An Affirmative Commitment and Access to Privacy Policy

AB Handshake Corporation complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce.

In this Policy we refer to the EU-U.S. DPF Principles and the UK Extension to the EU-U.S. DPF as the DPF Principles.

You can find the list of EU-U.S. DPF participants here.

AB Handshake Corporation has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.

If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern.

To learn more about the Data Privacy Framework (DPF) Program, Data Privacy Principles, and to view our certification, please visit https://www.dataprivacyframework.gov

AB Handshake Corporation has certified that it adheres to the DPF Principles with respect to personal data received from clients from the EU or the UK in reliance on the DPF.

When we act as a controller of personal data, we do not rely on the DPF Principles for the transfer of that data from the EU, or UK.

DPF Principles:

• Notice
• Choice
  AB Handshake Corporation acts as a processor of the personal data that is transferred to us in the U.S. by, or on behalf of, our clients in the EU or the UK. Our clients (or our clients’ clients) are responsible for providing certain choices to data subjects about the use of their personal data. AB Handshake Corporation will assist our clients with their response to data subjects who wish to exercise their choices regarding their personal data.
• Accountability for Onward Transfer
  As part of our commitment to transparency and compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, AB Handshake Corporation ensures that individuals are informed about our liability in cases of onward transfers to third parties.
  
  AB Handshake Corporation remains responsible for the processing of personal information it receives under the DPF Principles and subsequently transfers to a third party acting as an agent (processor).
  
  AB Handshake Corporation shall remain liable under the DPF Principles if its agent processes such personal information in a manner inconsistent with the DPF Principles, unless AB Handshake Corporation can demonstrate that it is not responsible for the event giving rise to the damage.
  
  We are committed to upholding the principles of data protection and ensuring accountability in all aspects of our data processing practices.
  
  AB Handshake Corporation may be required to disclose personal covered by DPF in response to lawful requests by public authorities, which may include complying with national security or law enforcement requirements.
• Security
  AB Handshake Corporation takes reasonable measures to protect your personal data from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss. To this end, AB Handshake Corporation implements and maintains appropriate processes, systems, and technologies.
  
  However, AB Handshake Corporation cannot be held liable for any unauthorized or unintended access to personal data that occurs beyond its control.
  
  Access to personal data is restricted to authorized employees who are trained in the proper handling of such information and who operate in accordance with internal policies and controls. AB Handshake Corporation conducts regular reviews to ensure employee compliance with these policies. Employees found to be in violation of our security and privacy policies may be subject to disciplinary action.
• Data Integrity and Purpose Limitation
  AB Handshake Corporation retains personal data covered by the DPF as instructed by its clients.
  
  Personal data may also be retained for a period of time necessary to comply with state, local, federal regulations, or country-specific regulations and requirements, and in accordance with AB Handshake Corporation applicable data retention policies.
  
  AB Handshake Corporation will not use the personal data covered by the DPF in a manner that is incompatible with the purpose for which it was originally collected, except as permitted by applicable law.
• Access, and Recourse
  When AB Handshake Corporation process personal data covered by the DPF, it acts as a processor for its clients. Clients are responsible for providing data subjects with access to that personal data, and the right to correct, amend or delete where it is inaccurate or where it has been processed in violation of the DPF Principles, as appropriate.
  
  As data subject You should direct your questions to the appropriate company.
  
  If You is unable to contact the appropriate company, or does not obtain a response from the client, AB Handshake Corporation will provide reasonable assistance in forwarding the data subject’s request to the relevant company.
• Enforcement and Liability
  AB Handshake Corporation is subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC), which has jurisdiction over AB Handshake Corporation’s compliance with the DPF Principles.
  
  In compliance with the DPF Principles, AB Handshake Corporation commits to resolve DPF Principles-related complaints about our collection or use of personal data included in the personal data covered by the DPF (transferred from our clients in the EU or the UK).
  
  You can learn how to file a complaint in the section Requests and complaints.

Designated Alternative Dispute Resolution Provider and Recourse Information

In compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, AB Handshake Corporation commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States.

If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit Data Privacy Framework Resolution | JAMS Mediation, Arbitration, ADR Services for more information or to file a complaint.

The services of JAMS are provided at no cost to you.

Federal Trade Commission (FTC) Oversight Disclosure

The Federal Trade Commission has jurisdiction over AB Handshake Corporation compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF.

Binding Arbitration Option Disclosure

In accordance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, AB Handshake Corporation acknowledges that individuals have the option, under certain conditions, to invoke binding arbitration as described in Annex I of the DPF Principles.

If any complaints regarding DPF compliance are not resolved through other mechanisms provided by the DPF Principles, individuals may choose to invoke binding arbitration. For more information on the conditions and procedures for invoking binding arbitration, please refer to Annex I of the DPF Principles.

Annex 1. List of processing

Annex 2. Category of data

Annex 3. Vendors