Global Privacy Policy

1 Our Institutional Commitment to Privacy

At Prime Global Bank National Association ("Prime Global Bank", "we", "us", or "our"), safeguarding your confidentiality and protecting your non-public personal information ("NPI") is paramount. We adhere to the highest international banking privacy standards, including Title V of the Gramm-Leach-Bliley Act (GLBA, 15 U.S.C. § 6801 et seq.), the California Consumer Privacy Act as amended by the CPRA, and the EU General Data Protection Regulation (GDPR).

This Privacy Policy explains the specific categories of data we gather, how that information is utilized to provide financial services, the stringent safeguards we enforce, and your legal rights regarding your data.

2 Categories of Information We Collect

In providing private, commercial, and digital asset banking services, we collect information from you through your application, transactions, and interactions with our digital infrastructure:

• Personal Identifiers: Full legal name, residential address, previous addresses, phone numbers, email address, date of birth, Social Security Number (SSN), Individual Taxpayer Identification Number (ITIN), passport number, or government-issued photo ID.
• Financial Information: Account numbers, transactional history, deposit records, balance inquiries, credit history, wire settlement routing instructions, and income / employment credentials.
• Digital Asset Records: Admin-assigned blockchain wallet addresses (Bitcoin, Ethereum, Tether), transaction hash records, spot buy/sell settlement timestamps, and digital custody logs.
• Device & Telemetry Data: IP address, device fingerprints, operating system specifications, browser attributes, geolocation telemetry, and cryptographic session cookies.
• Security Credentials: Encrypted password hashes, 4-digit wire PIN hashes, two-factor authentication logs, and one-time verification response tokens.

3 How We Use Your Information

We utilize your personal and financial information exclusively for lawful institutional purposes:

• Administering and operating your checking, savings, card, and digital custody accounts.
• Executing financial transactions across domestic Fedwire, ACH, international SWIFT, and crypto rails.
• Detecting, investigating, and mitigating fraud, unauthorized access, identity theft, or financial crimes.
• Complying with statutory reporting requirements (IRS, FinCEN, OFAC, Bank Secrecy Act).
• Facilitating tailored relationship management through your assigned wealth advisor.

4 Information Sharing & Disclosures

We disclose your non-public personal information only in limited, legally defined circumstances:

• Clearing & Settlement Partners: Correspondent banks, the Federal Reserve Bank, payment clearing networks (Visa, Mastercard), and custodial liquidity providers necessary to clear your transactions.
• Authorized Service Providers: Certified third-party technology providers (cloud hosting, SMS gateways, encrypted storage) operating under non-disclosure agreements and strict data protection contracts.
• Legal & Regulatory Mandates: To law enforcement, regulatory agencies (OCC, FDIC, FinCEN), or courts in response to lawful subpoenas, warrants, or court orders.

5 Cryptographic Security & Data Safeguards

We implement comprehensive administrative, technical, and physical safeguards designed to ensure the confidentiality, integrity, and availability of client records:

• Encryption Standards: All data in transit is encrypted using TLS 1.3 with SHA-256 ciphers. All data at rest in our databases and cold-storage vaults is protected with AES-256 military-grade encryption.
• Hardware Isolation: Administrative access to client wallets and wire desks requires hardware security keys, multi-party computation (MPC), and dual-operator authorization.
• Continuous Monitoring: Real-time intrusion detection systems, automated DDoS mitigation, and continuous vulnerability audits.

6 Your Legal Rights & Privacy Choices

Depending on your jurisdiction (including California and the European Economic Area), you possess specific privacy rights:

• Right to Know & Access: You may request a copy of the specific categories and pieces of personal information we have collected about you.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal records.
• Right to Restrict Processing: You may opt out of non-essential communications or specific processing activities not required for legal banking compliance.
• Right to Non-Discrimination: We will never discriminate against you, alter your rates, or deny banking services because you exercised your privacy rights.

7 Data Retention Policy

In accordance with federal banking laws (including the Bank Secrecy Act and FinCEN regulations), financial institutions are required to retain client identification and transactional records for a minimum of five (5) to seven (7) years following account closure. Following the expiration of statutory retention obligations, records are permanently purged using cryptographic data sanitization standards.

8 Contact Our Data Protection Officer

If you have questions, comments, or wish to submit a privacy rights request under CCPA or GDPR, please contact our Data Governance Office: