Privacy and Protection of Personal Information Policy

ICCS Americas is committed to protecting the privacy and security of personal information entrusted to us by our clients, employees, customers and other stakeholders. Personal information is handled confidentially and used only for legitimate business, operational, contractual or legal purposes. ICCS Americas maintains practices designed to protect personal information from unauthorized access, use, disclosure, alteration or loss.

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All employees are required to comply with ICCS Americas' privacy and information security policies and procedures. Employees receive training on the appropriate handling of personal and confidential information and on applicable privacy and data protection requirements. When privacy requirements or internal policies change, employees are informed of the changes and provided with additional guidance or training where appropriate.

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ICCS Americas respects applicable U.S. federal and state privacy requirements, including privacy and data security requirements applicable in Alabama. Where applicable, ICCS Americas will maintain processes for addressing individual privacy rights and responding to requests concerning personal information in accordance with the laws governing the individual and the information involved.

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Measures to Ensure the Security, Privacy & Integrity of Data

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ICCS Americas considers information security and privacy to be of the utmost importance. Our IT security structure is centrally managed, with documented policies and procedures governing the protection of systems and information. These policies are communicated to employees, and access to information is restricted according to authorized business responsibilities.

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External access to ICCS Americas systems is controlled through secured access methods and unique user accounts. Systems containing private or confidential information are not publicly accessible. Data transmitted to and from our systems is protected through secured file-transfer and encryption technologies, including SFTP using TLS 1.2 or PGP encryption, where applicable.

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Access to ICCS Americas systems is limited to authorized personnel and approved service providers based on legitimate business requirements. When an employee leaves the organization or no longer requires access, system and facility access is revoked in accordance with established procedures. ICCS Americas maintains processes for security incident response, data protection, backup and recovery, and the secure disposal of information.

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ICCS Americas Security Policies cover the following:

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• Application & Data Security

• Logical Security – Access & Authentication

• Physical Security – Systems & Facilities

• Building Security

• Data Center Security

• Processing Location Security

• Network & Communication Security

• Malicious Software Security

• Incident Response – Audit & Monitoring

• Backup and Recovery

• Disposal of Information

• Use of Other Vendors

• Security Incident Handling Policy