Compliance

By providing services to the customer, Lock Trust acknowledges and agrees that it is responsible for maintaining the security of any account data it possesses, stores, processes, or transmits on behalf of the customer, or to the extent that it could impact the security of the customer’s Cardholder Data Environment (CDE) and cardholder data, in accordance with the Payment Card Industry Data Security Standard (PCI DSS) and any other applicable laws, regulations, or industry standards. Lock Trust further acknowledges and agrees to implement and maintain appropriate security measures and controls to safeguard such data, including but not limited to encryption, access controls, monitoring, and incident response. Lock Trust shall promptly notify the entity of any actual or suspected security breach or unauthorized access to such data and shall cooperate with the entity in investigating and resolving such incidents. This provision shall survive the termination or expiration of any agreement or relationship between the parties.

Key Points

•    LT is a registered corporation and maintains good standing status in the USA, and other jurisdictions as required by law.
•    LT operates electronic International financial transactions for its members.
•    LT does not share confidential banking, credit or debit card information unless a fraud is suspected or if subpoenaed by the proper authorities.
•    LT is not a bank
•    LT does not pay interest on your credit balance
•    LT is audited regularly by the international audit firm.
•    LT maintains PCI DSS level 1 Compliance
•    LT is maintains Tenable io Certification using bank strength firewall hardware
•    LT is Tenable io Hack Certified with no penetration achievable

The Code of Conduct for the Credit and Debit Card Industry in Canada

LT Canada abides by, and requires its participants to comply with, the voluntary Code of Conduct for the Credit and Debit Card Industry (the Code of Conduct), The Code of Conduct was introduced by the Minister of Finance on May 17, 2010 and amended on April 13, 2015.

To review the Code of Conduct, please visit the Financial Consumer Agency of Canada (FCAC) website at:

 

https://www.canada.ca/en/financial-consumer-agency/services/industry/laws-regulations/credit-debit-code-conduct.html

Cross Border Data Transfers

The parties agree that Lock Trust may transfer Customer Data Processed under this Addendum outside the country where it was collected as necessary to provide the Payment Services. If Lock Trust transfers Customer Data protected under this Addendum to a jurisdiction for which the applicable regulatory authority for the country in which the data was collected has not issued an adequacy decision, Lock Trust will ensure that appropriate safeguards have been implemented for the transfer of Customer Data in accordance with applicable Data Protection Laws. For example, and for purposes of compliance with the GDPR, we rely on Binding Corporate Rules approved by competent supervisory authorities and other data transfer mechanisms for transfers of Customer Data within the Lock Trust Group.

 

With respect to your data transfers to Lock Trust of your Customers located in the European Union, Switzerland, the Europeans Economic Area, and/or their member states or the United Kingdom, we each agree that (i) to the extent applicable, your signing of the Agreement will be deemed to be signature and acceptance of the European Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to the GDPR (“EU Transfer Clauses”) by Merchant, as the data exporter and in the role of controller, and will be deemed to be signature and acceptance of the standard data protection clauses specified in regulations made by the Secretary of State under section 17C(b) of the 2018 Data Protection Act and for the time being, in force in the United Kingdom (the “UK Transfer Clauses”), as the data exporter (ii) to the extent applicable, Lock Trust’s signature of the Agreement will be deemed to be signature and acceptance of the EU Transfer Clauses by Lock Trust , as the data importer and in the role of controller, and will be deemed to be signature and acceptance of the UK Transfer Clauses, as the data importer; and (iii) the parties shall be subject to the Module 1 provisions of the EU Transfer Clauses. In the event the European Commission or the UK Secretary of State (or other applicable UK authorized body) revises and thereafter publishes new EU Transfer Clauses or UK Transfer Clauses, respectively (or as otherwise required or implemented by the European Commission or the UK Secretary of State (or other applicable UK authorized body)), the Parties agree that such new EU Transfer Clauses or UK Transfer Clauses, as applicable, will supersede the present EU Transfer Clauses or UK Transfer Clauses, as applicable, and that the parties agree to take all such actions required to effect the execution of the new EU Transfer Clauses or UK Transfer Clauses, as applicable. The EU Transfer Clauses (Module 1) and the UK Transfer Clauses will be incorporated into the Agreement by reference and will be considered duly executed between the parties upon entering into force of this Agreement subject to the following details:

A) EU Transfer Clauses

  1. option 1 of Clause 17 (Governing law) shall apply and the laws of Luxembourg shall govern the EU Clauses;
  2. in accordance with Clause 18 (Choice of forum and jurisdiction), the courts of Luxembourg will resolve any dispute arising out of the EU Clauses; and
  3. The parties agree that the details required under the EU Transfer Clauses Appendix are as set forth on Attachment 1.

B) UK Transfer Clauses

 

  1. Clause II(h)(iii) is incorporated and signature of the Agreement by Lock Trust will be deemed the requisite initials from Lock Trust as the data importer;
  2. The parties agree that the details required under Annex B of the UK Transfer Clauses are as set forth on Attachment 1 (to the extent applicable).

Attachment 1

Appendix to the EU Transfer Clauses and Annex B of the UK Transfer Clauses

A. The following is applicable, to the extent required, under the EU Transfer Clauses and the UK Transfer Clauses

Annex 1.A. List of Parties

Data Exporter

  • Name and Address: The data exporter is the Merchant and the address is as provided in the Agreement
  • Contact person’s name, position and contact details: as provided in the Agreement
  • Activities relevant to the data transferred under the Standard Contractual Clause: as provided in the Agreement
  • Signature and date: please see the “Cross Border Transfers” section of this Addendum
  • Role (controller/processor): controller

Data Importer

  • Name and Address: The data importer is Lock Trust and the address is as provided in the Agreement
  • Contact person’s name, position and contact details: as provided in the Agreement
  • Activities relevant to the data transferred under the Standard Contractual Clause: as provided in the Agreement Signature and date: please see the “Cross Border Transfers” section of this Addendum
  • Role (controller/processor): controller

Annex 1.B. Description of Transfer

Data subjects Whose Personal Data is Transferred
The Personal Data transferred concern the following categories of data subjects:

  • The data exporter’s customers, employees and other business contacts.

Categories of Personal Data Transferred

The personal data transferred may include the following categories of data:

  • Name, amount to be charged, date/time, bank account details, payment card details, CVC code, post code, country code, address, email address, fax, phone, website, expiry data, shipping details, tax status, unique customer identifier, IP Address, location, and any other data received by Lock Trust under the Agreement.

Sensitive data (if appropriate) and Applied Restrictions or Safeguards
The personal data transferred concern the following categories of sensitive data:

  • Not applicable, unless Merchant configures the service to capture such data.

Applies restrictions and safeguards:

  • Not applicable, unless Merchant configures the service to capture such data.

Nature of the Processing

As set forth in the Agreement.

Purpose(s) of the Transfer(s)

The transfer is made for the following purposes:

  • Performance of the services provided by data importer to data exporter in accordance with the Agreement.
  • To identify fraudulent activity and risk that is, or may, affect the data importer, the data exporter or other customers of the data importer.
  • To comply with laws applicable to the data importer.
  • As set forth in the Data Protection Addendum.

The Period for which the Personal Data will be Retained, or, if that is not Possible, the Criteria Used to Determine that Period

The data importer only retains the personal data for as long as is necessary with regards the relevant purpose(s) it was collected for (please see purposes above). To determine the appropriate retention period for personal data, the data importer considers the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of the personal data, the purposes for which the personal data is processed and whether such purposes can be achieved through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

For transfers to (Sub-) Processors, also Specify Subject Matter, Nature and Duration of the Processing

The data importer may share personal data with third-party service providers that perform services and functions at the data importer’s direction and on its behalf. These third-party service providers may, for example, provide an element of the services provided under the Agreement such as customer verification, transaction processing or customer support, or provide a service to the data importer that supports the services provided under the agreement such as storage. When determining the duration of the processing undertaken by the third-party service providers, the data importer applies the criteria provided above in this Annex 1.B.

Annex 1.C. Supervisory Authority

In accordance with Clause 13(a) of the EU Transfer Clauses, the supervisory authority with responsibility for ensuring compliance by the data exporter with Regulation (EU) 2016/679 as regards the data transfer, as indicated shall act as competent supervisory authority.

Annex II. Technical and Organizational Measures Including Technical and Organizational Measures to Ensure the Security of the Data

  1. Pseudonymization, Encryption and the Protection of Data During Transmission.

Lock Trust’s policies ensure compliance with this principle and require the use of technical controls to prevent the risk of disclosure of personal data. Lock Trust employs encryption in transit and at rest for all personal data. We also employ industry standard pseudonymization techniques, such as tokenization to protect personal data where applicable. Lock Trust has comprehensive policies that provide key obligations and processes to protect data when it is transferred within the enterprise and externally with third parties.

  1. Change Management and Business Continuity.

Lock Trust’s robust change management process protects the ongoing availability and resiliency of data and systems throughout their lifecycle by ensuring that changes are planned, approved, executed, and reviewed appropriately. The Company’s business continuity management process provides a framework for building organizational resilience with the capability of an effective response that safeguards the interests of its key stakeholders.

  1. Disaster Recovery.

Lock Trust’s robust disaster recovery program has processes for recovering information or technology systems in the event of any significant disruption, focusing on the IT systems that support critical business processes and customer activities. Lock Trust’s technology infrastructure is housed in multiple secure data centers, with primary and secondary capability, each equipped with network and security infrastructure, dedicated application and database servers and storage.

  1. Regular Testing, Assessment and Evaluating Effectiveness of Technical and Organizational measures.

Lock Trust regularly plans, executes and reports on the results of the Company’s testing program to assess and evaluate the effectiveness of its technological and organizational measures. The program is managed through our enterprise risk and compliance team who work with relevant stakeholders to obtain and evaluate information required for testing, reporting and remediating as necessary.

  1. User Identification and Authorization.

Lock Trust’s access management processes require users to log into the corporate network using a unique corporate network account ID and password for user identification and authentication before accessing any other in-scope applications. Automated policies regarding password composition, length, change, reuse, and lockout are applied. Role-based access and approvals, which are certified quarterly, are implemented across all in-scope systems to enforce least privileged principle.

  1. Physical Security of Locations Where Personal Data is Processed.

Lock Trust global safety and security policies and processes set forth the requirements necessary to facilitate sounds safety and security processes, including physical security, in accordance with applicable laws, regulations and partner requirements. Special emphasis is placed on security systems and safeguards when constructing special or sensitive areas such as mail rooms, equipment storage, shipping and receiving areas, computer/server rooms, communications vaults or classified document/information storage areas in accordance with the Company’s information security handling standard.

  1. Events Logging and Configuration.

Lock Trust has outlined and defined event logging and monitoring types and attributes. The Company collects and aggregates several types of logs to the centralized security monitoring system. Standard configuration management control is in place to ensure logs are collected from the systems, and then forwarded to our centralized security monitoring system. Lock Trust policies and supporting processes set forth that system configuration and hardening baselines must be implemented across all systems.

  1. IT Governance and Management; Certification and Assurance of Processes and Products.

Lock Trust promotes a strong security philosophy across the Company. Our Chief Information Security Officer oversees information security across our global enterprise. As part of our Enterprise Risk and Compliance Management Program, our Technology Oversight and Information Security Program is designed to support the Company in managing technology and information security risks and identifying, protecting, detecting, responding to and recovering from information security threats. Lock Trust certifies and assures its processes and products through a variety of enterprise programs, including (i) audits and assessments of Lock Trust’s technical industry standard obligations including but not limited to, ISO 27001, Payment Card Industry’s (PCI) applicable standards (DSS, PIN, P2PE, etc.) and the American Institute of Certified Public Accountants (AICPA) SOC-1 and SOC-2, (ii) Risk Control Identification Process (RCIP) which ensures early engagement and a standard approach to the measurement, management, and monitoring of risk associated with the development and release of product solutions, (iii) privacy impact assessments which are integrated into the early stages of the product and software development processes, and (iv) a comprehensive third party management program, which provides assurance through continuous management of risks throughout the lifecycle of an engagement with a third party.

  1. Data Minimization.

Our policies require, through technical controls, that data elements collected and generated are those which are adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed. Lock Trust’s privacy impact assessment processes ensure compliance with these policies.

  1. Data Quality and Retention.

Lock Trust’s access and quality policy ensures that all personal data is correct, complete, and up to date, enabling individual users to access the system to correct and modify their particulars (e.g., address, contact details etc.), and, where a request for correction is received from a data subject, to provide a service which delivers their right to correction. Our data governance program monitors data quality, issues and remediations, as necessary. We require that all data be classified according to its business value with assigned retention periods, which is based upon Lock Trust’s legal, regulatory, and business recordkeeping requirements. Upon expiration of the retention period, data and information is disposed, deleted, or destroyed.

  1. Accountability.

Lock Trust has developed a set of information security, technology, data governance, third party management and privacy policies and principles that are aligned to industry standards and designed to engage stakeholder collaboration and partnership in awareness and compliance with such policies and controls across the organization to ensure participation and accountability from the top down across the organization. Each program defines accountabilities for cross-functional data related decisions, processes and controls. As a data controller, Lock Trust is responsible for and demonstrates compliance with the relevant articles carrying an accountability obligation in the GDPR and other applicable data protection laws through the implementation of a privacy program policy and an underlying layered organizational and technical control structure to ensure enterprise-wide compliance with privacy law, regulation, policy, and procedures. These include being able to demonstrate compliance with the data protection laws through: 1) a strong culture of compliance, 2) an enterprise risk and compliance governance structure which includes management committees, oversight roles, privacy reporting, 3) business function accountability for compliance with the privacy program including establishment, documentation and maintenance of business processes and controls, 4) a global privacy department within the Enterprise Compliance Organization to oversee business compliance with the privacy program and define policies, standards, procedures, and tools which are operationalized by business functions, 5) communications to the enterprise by the global privacy function to promote awareness and understanding of privacy, 6) Enterprise Risk and Compliance Management Framework to ensure the use of consistent processes including privacy impact assessments, privacy monitoring and testing, privacy issue management, privacy training, annual privacy plan, and 7) reporting and analysis to management committees which oversee the Privacy Program.

  1. Data Subject Rights.

Lock Trust has a program in place to ensure data subject rights are fulfilled, including access, correction and erasure. Data erasure requests are fulfilled unless Lock Trust has a legal, regulatory obligation or other legitimate business reason to retain it. Lock Trust’s policies ensures that erasure occurs throughout the customer lifecycle.

  1. Processors.

Lock Trust has a comprehensive third-party management program, which provides assurance through continuous management of risks throughout the lifecycle of an engagement with a third party. We have contractual controls in place to require our processors and their sub processors to put in place comprehensive data security and privacy standards throughout the processing chain. All sub processors must require our advance approval before being engaged.

B. The following is applicable to UK Transfer Clauses only

Recipients
The personal data transferred may be disclosed only to the following recipients:

  • The data importer’s service providers (as further detailed above), affiliates, and personnel performing services in accordance with the Agreement.

Data protection registration information of data exporter (where applicable)

Not applicable.

Additional useful information (storage limits and other relevant information)

As set forth in the Agreement and above in this Attachment 1.

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