1. Objective

The purpose of this policy is to maintain the privacy of and protect the personal information of employees, contractors, vendors, interns, associates, subscribers, and business partners of Sanctm, Inc. (hereafter referred to as “SANCTM” or “the organization”) and ensure compliance with laws and regulations applicable to Sanctm.

2. Scope

This Policy applies to all SANCTM employees, contractors, vendors, interns, associates, subscribers, and business partners who receive personal information from SANCTM, who have access to personal information collected or processed by SANCTM, or who provide information to SANCTM, regardless of geographic location. All employees of the organization are expected to support the privacy policy and principles when they collect and/or handle personal information or are involved in the process of maintaining or disposing of personal information. This policy provides the information to successfully meet the organization’s commitment towards data privacy.

All partner firms and any Third Party working with or for SANCTM, and who have or may have access to personal information, will be expected to have read, understand, and comply with this policy. No Third Party may access personal information held by the organization without having first entered
into a confidentiality agreement.

3. Responsibilities

The owner for the Data Privacy Policy shall be the Data Privacy Officer. The Data Privacy Officer shall be responsible for maintenance and accuracy of this policy. Any queries regarding the implementation of this Policy shall be directed to the Data Privacy Officer. This policy may be reviewed for updates by General Counsel for the organization on an annual basis. Additionally, the data privacy policy shall be updated in-line with any major changes within
the organization’s operating environment or on recommendations provided by internal or external auditors.

4. Policy Compliance

Compliance with the data privacy policy shall be reviewed on a periodic basis by internal audit to ensure compliance monitoring through the implementation of compliance measurements and periodic review processes.

In cases where non-compliance is identified, the Data Privacy Officer shall review the reasons for such non-compliance along with a plan for remediation and report them to the Executive Team.

Depending on the conclusions of the review, need for a revision to the policy may be identified. In instances of persistent non-compliance by the individual(s) concerned, they shall be subject to action in accordance with the SANCTM Disciplinary Policy.

5. Data Privacy Principles

This Policy describes generally acceptable privacy principles (GAPP) for the protection and appropriate use of personal information at SANCTM. These principles shall govern the use, collection, disposal, and transfer of personal information, except as specifically provided by this Policy or as required by applicable laws:

• Notice: SANCTM shall provide data subjects with notice about how it collects, uses, retains, and discloses personal information about them.
• Consent: Use of SANCTM’s website and/or services shall constitute consent by the user / subscriber for SANCTM to collect, disseminate, store, hold, or distribute the user’s / subscriber’s personal information and other data under the terms of this privacy policy.
• Rights of Data subject: SANCTM shall provide individuals with the right to control their personal information within the organization’s systems that may be distributed to vendors or providers. This includes the right to access, modify, erase, restrict, transmit, or object to certain uses of their information and for withdrawal of earlier given consent to the notice.
• Collection: SANCTM shall collect personal information from data subjects only for the purposes identified in the privacy notice / subscription agreements and only to provide requested products or services.
• Use, Retention and Disposal: SANCTM shall only use personal information that has been collected for the purposes identified in the privacy notice / subscription agreements and in accordance with the consent that the data subject shall provide. SANCTM shall not retain personal information longer than is necessary to fulfil the purposes for which it was collected and to maintain reasonable business records. SANCTM shall dispose of the personal information once it has served its intended purpose or as specified by the data subject.
• Access: SANCTM shall allow data subjects to make inquiries regarding the personal information about them, that SANCTM shall hold and, when appropriate, shall provide access to their personal information for review, and/or update.
• Disclosure to Third Parties: SANCTM shall disclose personal information to Third Parties / partner firms only for purposes identified in the privacy notice and/or subscription agreements. SANCTM shall disclose personal information in a secure manner, with assurances of protection by those parties, according to the contracts, laws and other segments, and, where needed, with the consent of the data subject.
• Obligations for Sub-processor: Where a processor (vendor or 3rd party acting on behalf of SANCTM) engages another processor (Sub-processor) for carrying out specific processing activities on behalf of SANCTM (controller), the same data protection obligations as set out in the contract or other legal act between SANCTM and the processor shall be imposed on the Sub-processor by way of a contract or other legal instrument, in particular providing sufficient guarantees to implement appropriate technical and organizational measures in such a manner that the processing will meet the requirements of this privacy policy. Where the Sub-processor fails to fulfil its data protection obligations, the initial processor (relevant vendor or 3rd party acting on behalf of SANCTM) shall remain fully liable to SANCTM for the performance of that Sub-processor’s obligations.
• Security for Privacy: SANCTM shall protect personal information from unauthorized access, data leakage, and misuse by all practicable means.
• Quality: SANCTM shall take steps to ensure that personal information in its records is accurate and relevant to the purposes for which it was collected.
• Monitoring and Enforcement: SANCTM shall monitor compliance with its privacy policies, both internally and with Third Parties, and establish the processes to address inquiries, complaints and disputes.

6. Notice

Notice shall be made readily accessible and available to data subjects before or at the time of collection of personal information or otherwise, notice shall be provided as soon as practicable thereafter. Notice shall be displayed clearly and conspicuously and shall be provided online (e.g. by posting it on the subscriber portal, website, sending emails, newsletters, etc.) and/or by offline methods (e.g. through postal mail, flyers, etc.).
In case of any cross-border, international transfer of personal information, the data subjects shall be informed by a notice sufficiently prior to the transfer.
Privacy notices may include:

• the organization’s operating jurisdictions; Third Parties involved; business segments and affiliates; lines of business; locations;
• types of personal information collected; sources of information; who is collecting the personal information, including contact information;
• the purpose of collecting the personal information;
• assurance that the personal information will be used only for the purpose identified in the notice and only if the implicit and / or explicit consent is provided unless a law or regulation specifically requires otherwise;
• any choices the data subject has regarding the use or disclosure of the information; the process data subject shall follow to exercise the choices;
• the process for a data subject to change contact preferences and ways in which the consent is obtained.
• collection process and how the information is collected; how the information is used including any onward transfer to Third-Parties;
• retention and disposal process for personal information; assurance that the personal information to be retained only as long as necessary to fulfil the stated purposes, or for a period specifically required by law or regulation and will be disposed-off securely or made anonymous post the identified purpose is completed;
• process of accessing personal information; the costs associated for accessing personal information (if any); process to update and/or correct the personal information; the resolution of disagreements related to personal information; how the information is protected from unauthorized access or use;
• how users will be notified of any changes made to privacy notice;
• disclosure process for Third Parties; the assurance that the personal information is disclosed to Third Parties only for the purpose identified; the remedial actions in place for any misuse of personal information by the Third Parties;
• security measures in place to protect the personal information; ways of maintaining
  quality of personal information;
• monitoring and enforcement mechanisms in place; description of the complaint channels available to data subjects; how the internal personnel, key stakeholders and the subscribers can contact the company related to any privacy complaints or breaches;
• relevant contact information and / or other reporting methods through which the complaints and/or breaches could be registered;
  • Consequences of not providing the requested information.

7. Consent

Consent refers to their agreement to the collection and use, often expressed by the way in which they exercise a choice option.

• SANCTM shall establish systems for the collection and documentation of data subject consents to the collection, processing, and/or transfer of personal data.
• Data subjects shall be informed about the choices available to them with respect to the collection, use, and disclosure of personal information.
• Consent shall be obtained electronically from the data subjects before or at the time of collecting personal information or as soon as practicable thereafter.
• The changes to a data subject’s preferences shall be managed and documented. Consent or withdrawal of consent shall be documented appropriately.
• The choices shall be implemented in a timely fashion and respected. If personal information is to be used for purposes not identified in the notice / subscription agreements at or prior to the time of collection, the new purpose shall be documented, the data subject shall be notified, and consent shall be obtained prior to such new use or purpose.
• The data collected may be used for marketing purposes, advertisements, etc.
• SANCTM shall review the privacy policies of the Third Parties and types of consent of Third Parties before accepting personal information from Third-Party data sources.

8. Collection of Personal Information

Personal information may be collected online or offline. Regardless of the collection method, the same privacy protection shall apply to all personal information.

• Personal information shall not be collected unless one of the following is fulfilled:
  o the data subject has provided a valid, informed, and free consent;
  o processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract;
  o processing is necessary for compliance with the organizations legal obligations;
  o processing is necessary to protect the vital interests of the data subject; or
  o processing is necessary for the performance of a task carried out in the public interest.
• Data subjects shall not be required to provide more personal information than is necessary. If any data not needed for providing a service or product is requested, such fields shall be clearly labelled as optional. Collection of personal information shall be avoided or limited when reasonably possible.
• Personal information shall be de-identified when the purposes of data collection can be achieved without personally identifiable information at reasonable cost.
• When using vendors to collect personal information on behalf of SANCTM, it shall ensure that the vendors comply with the privacy requirements of SANCTM as defined in this policy.
• SANCTM shall at minimum, periodically review and monitor the information collected, the consent obtained and the notice and/or subscription agreement identifying the purpose.
• The project team/support function shall obtain approval from the IT Security team before adopting the new methods for collecting personal information electronically.
• SANCTM shall review the privacy policies and collection methods of Third Parties before accepting personal information from Third Party data sources.

9. Use, Retention and Disposal

• Personal information may only be used for the purposes identified in the notice and/or subscription agreements and only if the data subject has given consent;
• Personal information shall be retained for as long as necessary for business purposes identified in the notice and/or subscription agreements at the time of collection or subsequently authorized by the data subjects.
• When the use of personal information is no longer necessary for business purposes, a method shall be in place to ensure that the information is destroyed in a manner sufficient to prevent unauthorized access to that information or is de-identified in a manner sufficient to make the data non-personally identifiable.
• SANCTM shall have a documented process to communicate changes in retention periods of personal information required by the business to the data subjects who are authorized to request those changes.
• Personal information shall be erased if their storage violates any of the organization’s data protection rules or if knowledge of the data is no longer required by SANCTM or for the benefit of the data subject.
• Additionally, SANCTM has the right to retain the personnel information for marketing, legal, and regulatory purpose and as per applicable data privacy laws.
• SANCTM shall perform an internal audit on an annual basis to ensure that personal information collected is used, retained, and disposed-off in compliance with the organization’s data privacy policy.

10.Access

SANCTM shall establish a mechanism to enable and facilitate exercise of data subject’s rights of access, blockage, erasure, opposition, rectification, and, where appropriate or required by applicable law, a system for giving notice of inappropriate exposure of personal information.

• Data subjects shall be entitled to obtain the details about their own personal information upon a request made and set forth in writing. SANCTM shall provide its response to a request within 72 hours of receipt of the written request.
• Written requests shall be sent via USPS certified mail to:
  Sanctm, Inc.
  503 North Main Street
  Suite #648
  Pueblo, CO 81003
• The data subjects shall have the right to correct or supplement erroneous, misleading, outdated, or incomplete personal information.
• Requests for access to or rectification of personal information shall be directed to the manager of the projects team or support function responsible for the personal information.
• The members of the compliance team shall record and document each access request as it is received, and the corresponding action taken.
• SANCTM shall provide personal information to the data subjects in a plain, simple format which is understandable (not in any code format).

11.Disclosure to Third Parties

Data Subject shall be informed in the privacy notice and/or subscription agreement, if personal information shall be disclosed to Third Parties and/or partner firms, and it shall be disclosed only for the purposes described in the privacy notice and/or subscription agreements and for which the data subject has provided consent.

• Personal information of data subjects may be disclosed to the Third Parties and/or partner firms only for reasons consistent with the purposes identified in the notice and/or subscription agreements or other purposes authorized by law.
• SANCTM shall notify the data subjects prior to disclosing personal information to Third Parties and/or partner firms for purposes not previously identified in the notice and/or subscription agreements.
• SANCTM shall communicate the privacy practices, procedures and the requirements for data privacy and protection to the Third Parties and/or partner firms.
• The Third Parties shall sign a NDA (Non-Disclosure Agreement) with SANCTM before any personal information is disclosed to the Third Parties partner firms. The NDA shall include the terms on non-disclosure of customer information.

12.Security

Information security policy and procedures shall be documented and implemented to ensure reasonable security for personal information collected, stored, used, transferred, and disposed of by SANCTM.

• Information asset labelling and handling guidelines shall include controls specific to the storage, retention, and transfer of personal information.
• Management shall establish procedures that maintain the logical and physical security of personal information.
• Management shall establish procedures that ensure protection of personal information against accidental disclosure due to natural disasters and environmental hazards.
• Incident response protocols are established and maintained in order to deal with incidents concerning personal data or privacy practices.

13.Quality

SANCTM shall maintain data integrity and quality, as appropriate for the intended purpose of personal data collection and use and ensure data is reliable, accurate, complete, and current.

• For this purpose, the general counsel and the compliance team shall have systems and procedures in place to ensure that personal information collected is accurate and complete for the business purposes for which it is to be used.
• SANCTM shall perform an annual assessment of the personal information collected to check for accuracy, completeness, and relevance of the personal information.

14.Monitoring and enforcement

14.1. Dispute Resolution and Recourse
SANCTM shall define and document an Incident and Breach Management policy which addresses privacy-related incidents and breaches.

• The incident and breach management program includes a clear escalation path up to the executive management, legal counsel, and the board based on type and/or severity of the privacy incident/breach.
• It shall define a process to register all the incidents/complaints and queries related to data privacy.
• SANCTM shall perform a periodic review of all the complaints related to data privacy to ensure that all the complaints are resolved in a timely manner and resolutions are documented and communicated to the data subjects.
• An escalation process for unresolved complaints and disputes which shall be designed and documented.
• Communication of privacy incident and/or breach reporting channels and the escalation matrix shall be provided to all the data subjects.

14.2. Dispute Resolution and Escalation Process for Employees
Employees with inquiries or complaints about the processing of their personal information shall first discuss the matter with their immediate supervisor. If the employee does not wish to raise an inquiry or complaint with an immediate manager, or if the manager and employee are unable to reach a satisfactory resolution of the issues raised, the employee shall bring the issue to the attention of the Executive Team.
14.3. Dispute Resolution and Escalation Process for Customer and/or Third Party
Subscribers / Third Parties with inquiries or complaints about the processing of their personal information shall bring the matter to the attention of the Communications Team in writing. Any disputes concerning the processing of the personal information of non-employees shall be
resolved through arbitration.
14.4. Compliance Review
The Data Privacy officer shall conduct an internal audit periodically to ensure compliance with the established privacy policies and applicable laws.

• The internal audit shall consist of the review of the following:
  ➢ personal information collected from data subjects;
  ➢ the purposes of the data collection and processing;
  ➢ the actual uses of the data;
  ➢ disclosures made about the purposes of the collection and use of such data;
  ➢ the existence and scope of any data subject consents to such activities;
  ➢ any legal obligations regarding the collection and processing of such data, and
  ➢ the scope, sufficiency, and implementation status of security measures.
• The Data Privacy officer shall document all the instances of non-compliance with privacy policies and procedures and report the same to the Executive Team.
• The Executive Team, along with the Data Privacy officer shall take actions on the findings from the internal audit and work on the recommendations for improvement of the privacy posture
• Any changes made to the policies shall be communicated to all the employees, shareholders and the subscribers and/or clients.