APPROPRIATE SOLUTIONS, INC.

Privacy Policy and Commitment as Data Processor

Appropriate Solutions, Inc. (ASI) is committed to ensuring your personal data is protected and not misused.

This letter is issued by ASI as a Data Processor under the guidelines of the European Union General Data Protection Regulation (EU GDPR). ASI also complies with the EU Privacy Shield Framework, the Swiss Privacy Shield Framework, and the Payment Card Industry Data Security Standard (PCI DSS) requirements. ASI has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.

This letter addresses the privacy of data stored and processed by ASI as part of the AppropriateSolutions.com website and custom contracts (the “Services”).

Please direct questions regarding ASI’s privacy and data security policy to our Data Protection Officer’s email: complianceAppropriateSolutions.com.

ASI is a Level 1 PCI DSS Validated Service Provider.

METADATA WE COLLECT AND PROCESS

ASI Services collect metadata in logs for the following purposes:

This metadata may include:

DATA RETENTION

CONSENT

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may exercise any of your rights in relation to your personal data by written notice to us. Our email address for this purpose is complianceAppropriateSolutions.com.

EU-BASED REPRESENTATIVE

Since the Company does not include, on a large scale, processing of special categories of data as referred to in Article 9(1) of the GDPR or processing of personal data relating to criminal convictions and offences referred to in Article 10 of the GDPR, and is unlikely to result in a risk to the rights and freedoms of natural persons, taking into account the nature, context, scope and purposes of the processing; it is not necessary for Company to have an EU-based GDPR representative per Article 27.

OUR DETAILS

Effective May 23, 2018; Revised January 2, 2020; Revised March 1, 2022

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