Online Privacy Notice

February 1, 2021

Fidelity National Information Services, Inc. (its subsidiaries and affiliates, collectively “FIS”) recognizes and respects the privacy expectations of today’s consumers and the requirements of applicable regulations in protecting their online privacy. FIS believes that making you aware of how we use your Personal Data, including sensitive Personal Data, as discussed further below, and to whom it is disclosed, will form the basis for a relationship of trust with the public that we serve.

FIS safeguards your privacy rights with respect to any data or information we receive that relates to you as an identified or identifiable natural person. For purposes of this Notice, we will call such data or information “Personal Data.” Personal Data will always be collected, used, and disclosed by FIS in accordance with the requirements and prohibitions of applicable laws or regulations.

This Notice explains how we collect, use, store, and share the Personal Data you provide us on FIS websites. If you use any FIS websites, you agree your use of these websites is subject to the terms of this Online Privacy Notice. The Terms of Use are also subject to the terms of any other agreement you, your employer or other person or company you are representing, may have with FIS, as appropriate.

The FIS Online Privacy Notice was developed not only to safeguard our clients’ privacy, but also to provide assurance that your privacy is of paramount importance to us. For further information, please review the FIS Privacy Policy which explains FIS’ data collection and usage practices in greater detail.

WHAT:

What kind of Personal Data does FIS collect online?

In the course of our business, FIS may collect Personal Data about you from the following sources:

• applications or other forms we receive from you or your authorized representative;
• our internet websites;
• public sources, such as vendors who may provide Personal Data needed for money laundering and trade sanctions compliance, so FIS may confirm you are not listed as a restricted party with whom FIS is legally prohibited from doing business; and
• any mobile websites or applications you visit.

HOW:

How does FIS safeguard the Personal Data it collects?

• FIS maintains physical, electronic, and procedural safeguards designed to protect your Personal Data from unauthorized access or intrusion. FIS limits access to the Personal Data only to those employees, contractors and agents who need such access in connection with providing products or services to you, to clients with whom you have a relationship, or for other legitimate business purposes. Some of these measures may include encryption, physical access security, user access security measures, or other technologies and tools, which FIS believes may enhance the security of its systems and facilities. FIS has no responsibility or liability for the security of information you provide to FIS transmitted via the Internet.
• FIS employees and contractors receive annual training regarding FIS’ privacy and information security policies and procedures. FIS understands protecting consumer privacy is an integral part of protecting our relationship with our clients.
• FIS has put in place procedures to deal with any suspected breach of Personal Data and will notify you and any applicable regulatory of a Personal Data breach where we are legally required to do so.

How does FIS use the Personal Data collected?

• FIS uses the data we collect to assist us in delivering products or services to our clients to provide them with information about such products or other legitimate business purposes.
• FIS does not seek to determine your identity when you simply browse our site; however, if you provide FIS with your contact information, such as by completing an online form or providing information in a job application, FIS will know your identity.
• FIS collects and uses geolocation information linked to your device when you use our mobile apps, with your permission, and where permitted by local law. FIS uses this data as part of its processes to prevent and detect fraudulent card use and send alerts. FIS retains geolocation information processed as part of a transaction for 180 days. Where permitted by local law, FIS may monitor your geolocation information in the background while the mobile app is being is being used. You can change location permissions at any time either directly in the mobile app or in your device settings.
• FIS may use cookies to aggregate information about the web pages you visit, so FIS can continue to improve the digital experience and improve our services. FIS does not provide your domain to third parties, other than to the vendors, such as those with whom we contract for website design and maintenance. These vendors are under contractual confidentiality requirements.
• FIS may disclose your Personal Data if regulatory obligations require FIS to do so, if FIS determines such disclosure is legally advisable or necessary in order to protect FIS’ rights, the rights of others, or in order to prevent harm.
• FIS will process your Personal Data in compliance with applicable laws. For example, we may confirm your IP address matches the location entered into our online forms or may confirm you are not listed as a restricted party with whom we are legally prohibited from doing business.
• We will only retain your data for as long as necessary to fulfil the purposes for which it was collected and in accordance with applicable law. We establish our retention periods within our company policies.

What is the legal basis for processing your Personal Data?

• FIS collects, uses, stores and otherwise processes Personal Data where necessary to provide a service which you request, where necessary to comply with a legal obligation, and where necessary pursuant to FIS' legitimate interests and where these interests are not overridden by your data protection rights. FIS may also process your Personal Data where you have given consent. Where FIS asks for consent, you are free to withhold or revoke it by opting out on the preferences page available on FIS’ website.

WHO:

Who has access to the Personal Data FIS collects?

• FIS limits access to Personal Data to those employees, contractors, business partners, or agents who require such access in connection with providing products or services to you or for other legitimate business purposes.

With whom does FIS share the Personal Data it collects?

Where appropriate or necessary to do so, FIS may share your Personal Data among our company affiliates. FIS also may disclose your Personal Data to:

• agents, brokers, business partners, or representatives to provide you with services you have requested;
• third-party contractors or service providers to enable FIS to provide services or other functions to you or to an FIS client whose services you have requested;
• regulatory authorities or public authorities to meet our legal requirements connected to the collection, retention, and disclosure of Personal Data, such as tax reporting or identification of money laundering;
• law enforcement in connection with investigations;
• respond to a civil or criminal subpoenas or court orders;
• a prospective buyer or seller in the event FIS sells or buys any business or assets;

FIS will disclose your Personal Data when you direct or give us permission, when we are required by law, or when we suspect fraudulent or criminal activities.

FIS may also disclose your Personal Data when otherwise permitted by applicable privacy laws, such as when disclosure is required to enforce our rights arising out of any agreement, transaction, or relationship with you or another party.

OTHER THINGS YOU NEED TO KNOW:

Website(s) are not directed at persons under the age of 18

Children’s privacy

FIS does not knowingly solicit or collect personally identifiable information from children under the age of thirteen (13) without verifiable parental consent. If FIS learns that a child under the age of thirteen (13) has submitted personally identifiable information online without parental consent, FIS will take all reasonable measures to delete such information from our databases and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law). If you become aware of any personally identifiable information we have collected from children under thirteen (13), please contact us at datarights@fisglobal.com.

FIS website(s) are not directed at persons under the age of 18. FIS does not knowingly collect, maintain, or use Personal Data from persons under the age of 18 on any FIS website. If you are under the age of 18 years, please do not register or otherwise provide information to FIS on an FIS website. Minors under 18 years of age may have the personal information that they provide to us deleted by sending an email requesting deletion to datarights@fisglobal.com. Please note that, while we make reasonable efforts to comply with such requests, deletion of your personal information does not ensure complete and comprehensive removal of that data from all systems.

Use of Cookies on website(s)

What are cookies?

• Cookies are text files containing small amounts of information, which are downloaded to your computer or mobile device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user’s device and the website pages that interest a user. For more information on FIS’ use of cookies and your options, review the FIS Cookie Notification. You can also find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu.
• Cookies do many different jobs, such as allowing you to navigate between pages efficiently, remembering your preferences, and generally improving the user experience. They can also help to verify the advertisements and other content you see online are more relevant to you and your interests. They can be set by the website you are visiting (known as first party cookies), or by another entity such as an advertising network (known as third party cookies). The cookies used on this website have been categorized on the basis of the four categories found in the International Chamber of Commerce United Kingdom (ICC UK) Cookie guide. We use the following types of cookies:
• “Session” cookies remain in your browser during your browser session only (e.g. until you leave the website).
• “Persistent” cookies remain in your browser after the session (unless deleted by you).
• “Performance” cookies collect information about your use of the website, such as webpages visited and any error messages you receive. The information they collect is aggregated and is not used to directly identify any particular visitor. Performance cookies are used to improve how a website works.
• “Functionality” cookies allow the website to remember any choices you make about the website (such as changes to text size, or customized pages) and enable services such as commenting on a blog.
• Some of these cookies are provided by third parties. For example, we use Google analytics cookies to allow us to analyze statistics on the numbers of visitors to our websites and how users interact with different features on the websites. We also use social media cookies to construct visitor interest models and assess user habits. These cookies are also used to show you relevant advertising.

What if I don’t want cookies?

• By using FIS’ website and allowing tracking, you agree we can place cookies and other similar technologies on your device as explained above. If you want to remove existing cookies from your device, you can do this by using your browser options. If you want to block future cookies being placed on your device, you can change your browser settings to do this. When you review your browser settings or options, you can identify the FIS cookies since they include “FIS” in the name. For more information on managing cookies, see www.allaboutcookies.org/manage-cookies or www.youronlinechoices.com.

How does FIS respond to “Do Not Track” signals?

• When visiting FIS’ corporate website, https://www.fisglobal.com/, users are not immediately tracked and have the option to accept cookies by selecting “Accept”. BY not selecting the “Accept” option or by blocking specific types of cookies, FIS will remove all analytic and cookie tracking, so the user may browse as an unknown visitor.
• Third Parties are not authorized to track users of our websites.

FIS websites may be linked to other websites

FIS websites may contain links to other websites. As you navigate our websites, you may click on links that take you to websites that belong to other business units or business partners affiliated with FIS. In addition, we may include links to third-party websites, which are not FIS business units or FIS affiliates. FIS is not responsible for the content or privacy practices of other non-FIS websites to which our websites link. If you are asked to provide information on one of these websites, we encourage you to carefully review their privacy policies before doing so.

Transfer of Personal Data to Other Countries

In the ordinary course of global business operations, FIS may need to make international transfers of Personal Data between its various branches and offices and selected service providers in many parts of the world. Some of the countries to which the data is transferred may not have equivalent privacy and data protection laws to those in the data subject’s country of residence. FIS has established a data protection program and has put in place data processing agreements to ensure that transfers of Personal Data are subject to appropriate safeguards. This may include the use of European Commission-approved model clauses and other appropriate data transfer arrangements.

Managing your preferences

FIS strives to provide you with choices and preferences regarding certain Personal Data uses, particularly around marketing and advertising. You may opt-out of receiving communications about FIS products and services by visiting our subscription preference center at any time: http://empower1.fisglobal.com/preferences-termsofuse.html.

Your Rights

What rights do I have with respect to my Personal Data that FIS may have collected?

• The laws of certain jurisdictions may afford you the right to access your Personal Data held by FIS and to request correction, amendment, portability, or deletion of your Personal Data held by FIS. In addition, where applicable, you may have the right to object to processing based on legitimate interests and to withdraw consent where consent forms the legal basis for processing. These rights may be limited, for example, if fulfilling a request would reveal Personal Data about another person, or if the processing is required by law or another compelling legitimate interest. If you have unresolved concerns, you have the right to complain to a data protection authority. FIS reserves the right, where permitted by law, to verify your identity, and to refuse such requests where appropriate.
• In some circumstances, FIS processes Personal Data on behalf of its clients and is subject to the control and instructions of its clients. If you believe FIS may have Personal Data about you due to services FIS provides or has provided to an FIS client with whom you have a relationship, it may not be possible for FIS to respond to your request. In that circumstance, please direct your request to the FIS client with which you have the relationship.
  
  Requests to FIS may be made in writing to the following address:
  
  Chief Privacy Officer
  FIS
  601 Riverside Avenue
  Jacksonville, FL 32204
  datarights@fisglobal.com
  
  Or by phone at 866-728-7033.
• If you are based in the European Economic Area (EEA) or Switzerland, you may contact our Data Protection Officer at the following address:
  
  Data Protection Officer
  FIS
  25 Canada Square, Canary Wharf
  London E14 5LQ
  United Kingdom
  data.protection@fisglobal.com

Online Privacy Notice Updates

We keep our Online Privacy Notice under regular review, and, therefore, it is subject to change. Please review this Notice periodically. Any changes will become effective when we post the revised Notice on the site. Your continued use of the site following these changes means that you accept the revised Notice.