Safe Harbor Policy

MTFX SAFE HARBOR PRIVACY POLICIES AND STATEMENTS

MTFX complies with the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from Switzerland. MTFX has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view MTFX’s certification, please visit: https://2016.export.gov/safeharbor/.

DEFINITIONS

FOR THE PURPOSES OF THIS POLICY:

• "Personal Information” shall refer to any information that (i) is transferred from the European Economic Area or Switzerland to MTFX in the United States, (ii) is about an identified or identifiable Individual, (iii) can be linked to that Individual and (iv) is recorded in any form.
• “Individual” means any natural or legal person, other than those acting in their capacity as Workers
• “Worker” means any person who was previously, is currently, or might in the future be engaged by a MTFX affiliate as an employee under contract of service or in any other capacity under a contract for service or any other arrangement to work for any MTFX affiliate (e.g. intern, temporary staff, contractor, job applicant, etc.), as well as any dependents, beneficiaries and other related persons about whom such person provides information to a MTFX affiliate in connection with such relationship with MTFX or its affiliate.

NOTICE

MTFX collects Personal in the course of (i) its interactions with students and other customers, (ii) its interactions with educational institutions and (iii) its support of its European affiliates’ business operations. For more information about our collection of information the purposes for which it is used, visit our US Privacy Policy page.

Where MTFX receives personal information from its subsidiaries, affiliates or other entities in the EEA and Switzerland, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the Individuals to whom such personal information relates.

CHOICE

OPT-OUT RIGHTS

MTFX will offer Individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a third party (other than MTFX’s service providers or as specified in the Onward Transfer section below), or (b) to be used for a purpose other than for what it was originally collected or subsequently authorised by the Individual.

ONWARD TRANSFER OF PERSONAL INFORMATION

MTFX offers the choices set forth in the Choices section regarding certain transfers to third parties. Note that MTFX may disclose Personal Information without offering Individuals an opportunity to opt out (i) if required to do so by law or a legal process, (ii) to law enforcement authorities, (iii) when MTFX believes disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual fraudulent illegal activity. For more information about transfers, visit our U.S. Privacy Policy page.

DATA INTEGRITY

MTFX shall take reasonable steps to ensure that Individual Personal Information is: (i) relevant for the purposes for which it was collected or authorised by the Individual, (ii) reliable for its intended use and (iii) information is accurate, complete and current. Please contact us or use our website to update your Personal Information as necessary.

ACCESS

MTFX will provide Individuals with reasonable access to examine Personal Information that it holds. MTFX will take reasonable steps to permit Individuals to correct, delete, change or challenge the accuracy of the data that is demonstrated to be inaccurate or incomplete.

Requests for access to Personal Information should be made as discussed in the Contact section below during normal business hours, in line with MTFX standard procedures and the frequency of access shall not be excessive.

Under the Safe Harbor Principals there are some exceptions to the obligation to provide access to Personal Information. For example, MTFX may restrict access to proprietary information, such as business plans or other such sensitive information. Granting of access shall be restricted where the burden of expensive of providing access will be disproportionate to the risks of the privacy of other persons, or in cases where the rights of others would be violated.

Should an Individual be denied access to Personal Information, MTFX shall provide the Individual with the reason(s) and a contact point.

SECURITY

ENFORCEMENT AND DISPUTE RESOLUTION

MTFX conducts an annual self-assessment or external independent verification to verify the accuracy of this Safe Harbor privacy policy and to verify that this policy is accurate, comprehensive for the Personal Information it is intended to cover, prominently displayed, implemented fully, accessible and conforms to the Safe Harbor principles.

Individuals may contact MTFX with any concerns or questions about this privacy policy at the contact address provided below. MTFX will investigate and attempt to resolve any concerns or complaints regarding Personal Information in accordance with this privacy statement and at the request of the Individual. If the issue cannot be resolved directly or satisfactorily through the internal dispute resolution mechanism, the Individual may submit the complaint for arbitration with the EU DPA’s dispute resolution panel.

For information about EU DPA’s dispute resolution dispute resolution process, visit the United States Council for International Business on the Internet at www.uscib.org. The EU DPA’s dispute resolution process shall be conducted in English.

AMENDMENTS

MTFX in its sole and absolute discretion, may change or modify this Policy at any time and such modifications shall be effective immediately upon the post of the amended Policy to www.mtfxgroup.com.