In the course of serving you as an individual purchaser, Ceiba Tree, SRL (“Ceiba Tree”) may obtain personal information about you. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.
EXHIBIT “B”, CEIBA TREE,
This policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy. As used throughout this policy, the term “Developer” refers to Ceiba Tree, SRL, LLC (“Ceiba Tree”)
The Sources of Information.
The personal information we collect about you comes primarily from the application or other forms and materials you submit to Developer during the course of your relationship with us. In addition, depending on the products or services you require, Ceiba Tree may obtain additional information about you, such as your credit history, from consumer reporting agencies.
Finally, in the provision of services to you and subject to strict compliance with all applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (e.g. recording of telephone calls and monitoring e-mails). In these circumstances, the information is not accessed on a continuous or routine basis, but it may be used for compliance or security purposes.
The Information We Have about You.
If you deal with Ceiba Tree in your individual capacity (e.g. as a private citizen), the typical information we collect about you would include:
- Your name, address and other contact details;
- Your age, occupation and marital status;
- A head and shoulders photograph from, as applicable, your passport, national identity card or driver’s license, as required by laws and regulations addressing due diligence and related matters; and
- A personal identifier such as, depending on your country of residence, your Social Security Number, National Insurance Number, Tax File Number, etc.
Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may result in our being unable to provide services to you. While we make every effort to ensure that all information we hold about you is accurate, complete and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal information.
Our Use of Your Personal Information.
We may use your personal information to:
- Administer, operate, facilitate and manage your relationship with Ceiba Tree. This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively;
- Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection with your relationship with us;
- Provide you with information regarding Ceiba Tree, SRL, and
- Facilitate our internal business operations and fulfilling our legal and regulatory requirements.
If your relationship with CEIBA TREE ends, CEIBA TREE will continue to treat your personal information, to the extent we retain it, as described in this policy.
Disclosures of Your Personal Information within CEIBA TREE, SRL.
In order to provide efficient and reliable services and to improve product and service options available to you, more than one entity within Ceiba Tree, SRL, may be given, or given access to, your personal information. When so sharing your personal information, we adhere to applicable legal and industry standards regarding the protection of personal information. Additional information on how your personal information is protected while within CEIBA TREE is provided below, under Information Security: How We Protect Your Privacy.
Disclosures of Your Personal Information to Third Parties.
CEIBA TREE does not disclose your personal information to third parties, except as described in this policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your purchase or facilitate your transaction with CEIBA TREE, including those that provide professional, legal or accounting advice to CEIBA TREE, non-affiliated companies that assist CEIBA TREE in providing services to you are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information only in the course of providing such services and only for the purposes that CEIBA TREE dictates.
We may also disclose your personal information to fulfill your instructions, to protect our rights and interests and those of our business partners or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations; for instance, when responding to a subpoena or similar legal process, to protect against fraud and to otherwise cooperate with law enforcement or regulatory authorities or with organizations such as exchanges and clearinghouses.
Information Security: How We Protect Your Privacy.
CEIBA TREE is committed to protecting the privacy and confidentiality of your personal information. We limit access to your personal information to authorized CEIBA TREE employees or agents and, as described above in Disclosures of Your Personal Information to Third Parties, our service providers are held to stringent standards of privacy. We also maintain physical, electronic and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure.
You should know that CEIBA TREE will not sell your personal information.