Chargebacks911 and its affiliates (including Disputelab.com, eConsumer Services, and Global Risk Technologies) have adopted this Privacy Policy ("Policy") to establish and maintain an adequate level of Personal Data privacy protection per the obligations set out under the Privacy Shield Framework. This Policy applies to the processing of Personal Data that Chargebacks911 obtains from Customers located in the European Union and Switzerland.

Chargebacks911 complies with the  EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework ("Privacy Shield") as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the  European Union and the United Kingdom and/or Switzerland, as applicable to the United States in reliance on Privacy Shield. Chargebacks911 has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information.  If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

All Chargebacks911 Employees who handle Personal Data from Europe are required to comply with the Principles stated in this Policy.

1. SCOPE

This Policy applies to the processing of Customer Personal Data and/or HR data that Chargebacks911 receives in the United States concerning either Customers and/or Chargeback911 EU human resource data. This Policy applies to all of our US legal entities, subsidiaries and/or affiliates (listed below under Other Covered Entities).

Other Covered Entities

• DisputeLab.com
• eConsumer Services
• Global Risk Technologies
• Artefacts Solutions, INC.
• FI911.COM

2. RESPONSIBILITIES AND MANAGEMENT

Chargebacks911 has designated its Legal Department to oversee its information security program, including its compliance with the Privacy Shield program. The Legal Department shall review and approve any material changes to this program as necessary. Any questions, concerns, or comments regarding this Policy also may be directed to legal@chargebacks911.com.

Chargebacks911 will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. Chargebacks911 personnel will receive training, as applicable, to effectively implement this Policy. Please refer to Section 6 for a discussion of the steps that Chargebacks911 has undertaken to protect Personal Data.

3. RENEWAL / VERIFICATION

Chargebacks911 will renew its Privacy Shield certification annually, unless it subsequently determines that it no longer needs such certification or if it employs a different adequacy mechanism. Prior to the re-certification, Chargebacks911 will conduct an in-house verification to ensure that its attestations and assertions with regard to its treatment of Customer Personal Data are accurate and that the company has appropriately implemented these practices. Specifically, as part of the verification process, Chargebacks911 will undertake the following:

• 3.1 Review this Privacy Shield policy and its publicly posted website privacy policy to ensure that these policies accurately describe the practices regarding the collection of Customer Personal Data;
• 3.2 Ensure that the publicly posted privacy policy informs Customers of Chargebacks911's participation in the Privacy Shield program and where to obtain a copy of additional information (e.g., a copy of this Policy);
• 3.3 Ensure that this Policy continues to comply with the Privacy Shield principles;
• 3.4 Confirm that Customers are made aware of the process for addressing complaints and any independent dispute resolution process (Chargebacks911 may do so through its publicly posted website, Customer contract, or both);
• 3.5 Review its processes and procedures for training Employees about Chargebacks911's participation in the Privacy Shield program and the appropriate handling of Customer Personal Data.

4. COLLECTION AND USE OF PERSONAL DATA

Chargebacks911 provides various solutions to its Customers, which are predominantly business Customers, and collects some Personal Data from Customers when they purchase our services, log in to their account, request information from Chargebacks911, or otherwise communicate with Chargebacks911. For example, Chargebacks911’s Customers may choose to seek live support or request transactional data concerning a chargeback or the associated customer to a transaction where a chargeback has occurred.

The Personal Data that Chargebacks911 collects may vary based on the Customers and their specific request for services. As a general matter, Chargebacks911 may collect the following types of Personal Data from its Customers: contact information, including, a contact person's name, work email address, work mailing address, work telephone number, title, and company name, as well as payment information (which might include credit card and/or bank account information). Customers have the option to log in to their accounts online and Chargebacks911 will collect information that Customers choose to provide to Chargebacks911 through these portals.

Chargebacks911 serves as a service provider to its Customers. In our capacity as a service provider, Chargebacks911 will receive, store, and/or process Personal Data owned and/or controlled by our Customers, including information about their employees, clients, customers, agents, or other individuals. In such cases, Chargebacks911 is acting as a data processor and will process the personal information on behalf of and under the direction of each Customer. The information collected from Chargebacks911’s Customers in this capacity is used for managing transactions, reporting, invoicing, renewals, other operations related to providing services to the Customer, and as otherwise requested by the Customer.

5. DISCLOSURES / ONWARD TRANSFERS OF PERSONAL DATA

Except as otherwise provided herein, Chargebacks911 discloses Personal Data only to a Third Party who reasonably need to know such data. Such recipients must agree to abide by confidentiality obligations. Chargebacks911 provides, upon request, Mutual Non-Disclosure Agreements for its Customers, which may be tailored based upon Customer’s individual business needs, as a means to control and limit the disclosure of Customer Personal Data.

Chargebacks911 may provide Personal Data to a Third Party that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. For example, Chargebacks911 may store such Personal Data in the facilities operated by a Third Party. Such Third Party must agree to use such Personal Data only for the purposes for which they have been engaged by Chargebacks911 and they must either: (1) comply with the Privacy Shield principles or another mechanism permitted by the applicable European data protection law(s) for transfers and processing of Personal Data; or (2) agree to provide adequate protections for the Personal Data that are no less protective than those set out in this Policy. Chargebacks911 also may disclose Personal Data for other purposes or to another Third Party when a Data Subject has consented to or requested such disclosure. In cases of onward transfer to third parties of data of E.U. or Swiss individuals, received pursuant to the E.U.-U.S. Privacy Shield and Swiss-U.S. Privacy Shield, Chargebacks911 is potentially liable.

6. DATA INTEGRITY AND SECURITY

Chargebacks911 uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. Chargebacks911 has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. For example, electronically-stored Personal Data is stored on a secure network with firewall protection, and access to Chargebacks911's electronic information systems requires user authentication via password or similar means. Chargebacks911 also employs access restrictions, limiting the scope of Employees who have access to Customer Personal Data. Further, Chargebacks911 uses secure encryption technology to protect certain categories of Personal Data. Despite these precautions, no data security safeguards can guarantee absolute security all of the time, and as such Chargebacks911 does not make any such guarantee.

7. NOTIFICATION

Chargebacks911 notifies Customers about its adherence to the Privacy Shield principles through its publicly posted website privacy policy, available at https://chargebacks911.com/privacy-policy/

8. ACCESSING PERSONAL DATA

Chargebacks911 personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.

9. RIGHT TO ACCESS, CHANGE OR DELETE PERSONAL DATA

• 9.1 Right to Access. Data Subjects have the right to know what Personal Data about them is included in the databases and to ensure that such Personal Data is accurate and relevant for the purposes for which Chargebacks911
  collected the Personal Data. Data Subjects may review their own Personal Data stored in the databases and correct, erase, or block any data that is incorrect, as permitted by applicable law. Upon reasonable request and as required by the
  Privacy Shield principles, Chargebacks911 allows Customers access to their Personal Data, in order to correct or amend such data where inaccurate. Customers may edit their Personal Data by contacting Chargebacks911 by phone or email. In
  making modifications to their Personal Data, Data Subjects must provide only truthful, complete, and accurate information. To request erasure of Personal Data, Customers should submit a written request of the same. Persons that have submitted
  their Personal Data to a Chargebacks911 Customer should contact the Customer in the first instance to update their data.
• 9.2 Requests for Personal Data. Chargebacks911 will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise: (a) legally binding
  request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation; or (b) requests received from the Data Subject. If Chargebacks911 receives a request for access to his/her Personal Data
  from a Customer's customer, then, unless otherwise required under law or by contract with such Customer, Chargebacks911 will refer such Data Subject to Customer.
• 9.3 Satisfying Requests for Access, Modifications, and Corrections. Chargebacks911 will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.

10. CHANGES TO THIS POLICY

This Policy may be amended from time to time, consistent with the Privacy Shield Principles and applicable data protection and privacy laws and principles. Chargebacks911 will make Employees aware of changes to this policy, and will notify Customers if any changes are made that materially affect the way that Personal Data is handled and previously collected, and Chargebacks911 will allow Customers to choose whether their Personal Data may be used in any materially different manner.

11. QUESTIONS OR COMPLAINTS

Customers may contact Chargebacks911 with questions or complaints concerning this Policy at the following address: legal@chargebacks911.com

12. ENFORCEMENT AND DISPUTE RESOLUTION

In compliance with the Privacy Shield Principles, Chargebacks911 commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Chargebacks911 at:

Brooke Sullivent
In-House Counsel
Chargebacks911
18167 US Highway 19 North Suite 250
Clearwater, Florida 33764
Email: legal@chargebacks911.com
Phone: (813) 421-0734

We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your EU Personal Data within 45 days of receiving your inquiry or complaint. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit your countries DPA for more information or to file a complaint.

Chargebacks911 has further committed to refer unresolved Privacy Shield complaints to the appropriate EU data protection authorities (DPAs) and/or the Swiss Federal Data Protection and Information Commissioner (FDPIC). The services of the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) are provided at no cost to you.

Under certain conditions, more fully described on the Privacy Shield Website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

13. Definitions

Capitalized terms in this Policy have the following meanings:

"Customer" means a prospective, current, or former partner (distributor or reseller), vendor, supplier, customer, or client of Chargebacks911. The term also shall include any individual agent, employee, representative, customer,
or client of a Chargebacks911 Customer where Chargebacks911 has obtained his or her Personal Data from such Customer as part of its business relationship with the Customer.

"Data Subject" means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her
personal physical, psychological, mental, economic, cultural or social characteristics. For Customers residing in Switzerland, a Data Subject also may include a legal entity.

"Employee" means an employee (whether temporary, permanent, part-time, or contract), former employee, independent contractor, or job applicant of Chargebacks911 or any of its affiliates or subsidiaries, who is also a resident
of a country within the European Economic Area.

"Europe" or "European" refers to a country in the European Economic Area.

"Personal Data" as defined under the European Union Directive 95/46/EC means data that personally identifies or may be used to personally identify a person, including an individual's name in combination with country of birth,
marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, email address, user ID, password, and identification numbers. Personal Data does not
include data that is de-identified, anonymous, or publicly available. For Switzerland, the term "person" includes both a natural person and a legal entity, regardless of the form of the legal entity.

"Third Party" means any individual or entity that is neither Chargebacks911 nor a Chargebacks911 employee, agent, contractor, or representative.