ZPLINTR'S COMPLIANCE POLICY WITH THE PROVISIONS OF THE GDPR

INTRODUCTION

In the interest of transparency towards its the compliance with the General Data Protection Regulation No. 2016/679 (hereinafter the "GDPR"), the Optionizr Company (hereinafter "Optionizr") has decided to list all its processes, subcontractors likely to host data for the proper functioning of its services.

OPTIONIZR’S LEGAL STATUS

OPTIONIZR may collect and / or process personal data of final consumers on behalf of the vendor that selling options, and as such is deemed to be a considered as Processor, within the meaning of article 4 of the GDPR.

SUBCONTRACTORS WHICH ARE LIKELY TO HOST DATA

·             OVH, a simplified joint-stock company (société par actions simplifiée), whose head office is located at 2 rue Kellermann - 59100 Roubaix, registered with the Lille Trade and Companies Register under number 424 761 419, used for hosting data.

·             Amazon Web Services LLC, P.O Box 81226, Seattle, WA 98108-1226, used for hosting data.

·             Sendgrid whose head office is located at 1081 California Street, Suite 500, CO 80202 Denver, for the sending of emails for the options’ service.

·             Infobip whose head office is located at 6th Floor, Clinch's House, Lord Street, Douglas, Isle of Man IM99 1RZ, for the sending of SMS for the options’ service.

DATA PROTECTION OFFICER

In accordance with the provisions of article 37 of the GDPR, Optionizr does not have a Data Protection Officer.

RECORDS OF PROCESSING ACTIVITIES

In accordance with the provisions of article 30 of the RGPD, although Optionizr currently has less than 250 employees, given the nature of its activities, the company has made the choice to maintain a record of processing activities.