Common use of Confidential Information and Personal Data Clause in Contracts

Confidential Information and Personal Data. a. Each party will use reasonable efforts to cause its employees to minimize distribution and duplication and prevent unapproved disclosure of Confidential Information. b. Aon and its Affiliates may use Client Data to produce reports, analysis, or results for services and disclose them to: Aon employees, agents, subcontractors, counsel and auditors; Client; and other Aon customers, provided that such Client Data is aggregated and is not individually identifiable. Due to the continued use of data in active and archival surveys,Client Data will not be returned or destroyed and will be retained in accordance with Aon’s corporate record retention schedules. c. Subject to Clause 3(d) and Clause 4(d), Client and its Approved Users may only disclose Aon Confidential Information to Affiliates for which Client Data has been submitted, Approved Consultants and the employees of such entities with a need to know such Aon Confidential Information. Client and its Approved Users will not disclose or make available Aon Confidential Information, including Aon Confidential Information contained in the Deliverables, to any other Client Affiliates, or to any other third party. d. Where Client or Approved Users disclose any Deliverables to its Affiliates, Client shall procure: a. the Deliverables are disclosed in full and no disclaimers are removed from the Deliverables prior to disclosure; b. that all such recipients accept such Deliverables: (i) on the basis Aon’s aggregate liability, collectively, to those recipients and Client is no greater than our aggregate liability to Client as set out in this Agreement and (ii) subject to an obligation not to disclose such Information to third parties, other than as required by law or court order. e. Client agrees that Aon may disclose that Client and/or Affiliates are participants in an applicable survey. Survey participant lists may show general company information specific to Client/Affiliates, including some or all of the following: (i) company name; (ii) industry;

Confidential Information and Personal Data. a. Each party The Agent agrees that it will use reasonable efforts to cause its employees to minimize distribution and duplication and prevent unapproved disclosure not, without the prior written consent of Confidential Information. b. Aon and its Affiliates may use Client Data to produce reports, analysis, or results for services and disclose them to: Aon employees, agents, subcontractors, counsel and auditors; Client; and other Aon customers, provided that such Client Data is aggregated and is not individually identifiable. Due to the continued use of data in active and archival surveys,Client Data will CUENTAS (which shall not be returned or destroyed and will be retained in accordance with Aon’s corporate record retention schedules. c. Subject to Clause 3(d) and Clause 4(dunreasonably withheld), Client and its Approved Users may only disclose Aon Confidential Information to Affiliates for which Client Data has been submitted, Approved Consultants and the employees of such entities with a need to know such Aon Confidential Information. Client and its Approved Users will not disclose or make available Aon Confidential Information, including Aon Confidential Information contained in the Deliverables, to any (other Client Affiliates, or to any other third party. d. Where Client or Approved Users disclose any Deliverables than to its Affiliates) any Confidential Information with respect to CUENTAS or the Payees furnished to it under this Agreement, Client shall procure: a. the Deliverables are disclosed in full and no disclaimers are removed from the Deliverables prior to disclosure; b. that all such recipients accept such Deliverables: except (i) on as may be required to comply with any applicable law or regulation or pursuant to legal process (and the basis Aon’s aggregate liability, collectivelyAgent agrees that it will, to those recipients the extent reasonably practicable and Client is no greater than our aggregate liability if permitted by applicable law and regulation or by the legal process, give CUENTAS prior written notice of such disclosure reasonably sufficient to Client as set out in this Agreement and (ii) subject permit CUENTAS to an obligation not to disclose contest such Information to third parties, other than as required by law or court order. e. Client agrees that Aon may disclose that Client and/or Affiliates are participants in an applicable survey. Survey participant lists may show general company information specific to Client/Affiliates, including some or all of the following: (i) company namedisclosure); (ii) industry;in connection with the exercise of any remedies hereunder or any suit, action or proceeding relating to this Agreement or the enforcement of rights hereunder and thereunder, and (iii) as has become generally available to the public, is already in the Agent’s possession, or has been given to the Agent by a third party that is not, to the Agent’s knowledge, breaching confidentiality obligations with respect to CUENTAS; provided, further, that in no event shall the Agent be obligated or required to return any materials furnished by CUENTAS. The provisions of this confidentiality shall remain in full force and effect for a period of at least three (3) years after the expiration or termination of this Agreement. Within ten (10) Business days of the expiration or termination of this Agreement, each Party shall return to the other any physical or written record containing Confidential Information. The Party that receives Confidential Information shall protect the confidentiality of any Confidential Information disclosed by the other Party using at least the degree of care that it uses to protect its own Confidential Information (but no less than a reasonable degree of care). The Party that receive the Confidential Information shall, prior to providing any Affiliate, employee, or consultant access to any Confidential Information of the other Party, inform such Affiliate, employee, or consultant of the confidential nature of such Confidential Information and require such Affiliate, employee, or consultant to comply with its obligations hereunder with respect to such Confidential Information. The Party that received the Confidential Information shall be responsible to the other Party for any violation of this Clause by any such Affiliate, employee, or consultant. Furthermore, with respect to the Personal Data gathered by Master Agent though the services provided to CUENTAS and Payees under this Agreement, Master Agent shall, and shall procure that each of its personnel, and its agents shall comply with all Data Protection Laws, to the extent applicable. The Master Agent represents and warrants to CUENTAS that it (i) shall implement appropriate technical and organizational measures in order to ensure their activities regarding the processing of Personal Information will meet the requirements of applicable Data Protection Laws, (ii) shall implement the necessary mechanisms and procedures to protect Personal Data in accordance with the levels required by the LFPDPPP, and (iii) it will ensure Personal Data is kept confidential.

Confidential Information and Personal Data. a. Each party will use reasonable efforts to cause its employees to minimize distribution and duplication and prevent unapproved disclosure of 10.1. The Parties have agreed that all information designated by the Customer in writing as “confidential” shall remain secret (hereinafter “Confidential Information”). b. Aon 10.2. The Parties have agreed that the Contractor shall not disclose any Confidential Information to any third party and its Affiliates may use Client Data shall take measures making it impossible for third parties to produce reportsaccess such Confidential Information. The provisions of the previous sentence shall not apply to cases where: 10.2.1. the Contractor is required to do otherwise by law or by a final decision issued by a court or an administrative authority; and/or 10.2.2. the Contractor has disclosed such information to persons who are obliged by law to maintain confidentiality providing that the Contractor informs the Customer in writing to which third party the Confidential Information was made accessible and has bound this third party by the same confidentiality obligation by which the Contractor is bound; and/or 10.2.3. such information becomes publicly known or available in any manner other than by a breach of the obligations resulting from this Article; and/or 10.2.4. the Customer agrees in writing with making particular Confidential Information accessible. 10.3. The Parties have agreed that the Customer is entitled to make this Contract and/or Confidential Information obtained on the basis of and/or in connection with the Contract accessible to all companies (including statutory bodies of these companies) that are members of the same concern as the Customer / form a concern with the Customer within the meaning of Sections 79 et seq. of Act No. 90/2012 Coll., analysison commercial companies and cooperatives (the Business Corporations Act), or results for services and disclose them to: Aon employeesas amended. 10.4. When performing this Contract, agents, subcontractors, counsel and auditors; Client; and other Aon customers, provided that such Client Data is aggregated and is not individually identifiable. Due the Parties undertake to the continued use of data in active and archival surveys,Client Data will not be returned or destroyed and will be retained proceed in accordance with Aon’s corporate record retention schedulesthe Regulation as well as with the Personal Data Processing Act. c. Subject 10.5. The Parties may process personal data solely for the purpose of performing the Contract. If the Contractor processes personal data for other purposes, it does so contrary to Clause 3(d) and Clause 4(d)the Contract, Client and its Approved Users may only disclose Aon Confidential Information to Affiliates for which Client Data has been submitted, Approved Consultants and the employees Customer is not responsible for such processing of such entities with a need to know such Aon Confidential Informationpersonal data. Client and its Approved Users will not disclose or make available Aon Confidential InformationIn this case, including Aon Confidential Information contained the Contractor is in the Deliverablesposition of the personal data controller pursuant to the Regulation and the Personal Data Processing Act in relation to these personal data. 10.6. The Contractor undertakes to process personal data for the term of the Contract and for a maximum period of the following three (3) months after its termination; after the expiration of this period, the Contractor undertakes to destroy such data. If the Contractor processes personal data after the expiration of the period thus determined, it does so contrary to the Contract, and the Customer is not responsible for such processing of personal data. In this case, the Contractor is in the position of the personal data controller pursuant to the Regulation and the Personal Data Processing Act in relation to these personal data. 10.7. Furthermore, the Contractor undertakes to secure the processing of personal data using technical and organizational measures so that personal data are sufficiently protected and handled in accordance with the Regulation and the Personal Data Processing Act. Personal data shall be processed using computer technology and access to them must be sufficiently secured to prevent unauthorized or accidental access to personal data, their unauthorized modification, destruction or any other Client Affiliates, abuse or misuse. 10.8. The Contractor undertakes not to combine personal data processed for the purpose of performing this Contract with any other third partypersonal data obtained or processed for any other reason. d. Where Client or Approved Users disclose any Deliverables 10.9. The Contractor is obliged to its Affiliates, Client shall procure: a. respect the Deliverables are disclosed in full data subject’s right to the protection of their private and no disclaimers are removed from personal lives and to the Deliverables prior to disclosure; b. that all such recipients accept such Deliverables: (i) on protection against unauthorized interference with the basis Aon’s aggregate liability, collectively, to those recipients private and Client is no greater than our aggregate liability to Client as set out in this Agreement and (ii) subject to an obligation not to disclose such Information to third parties, other than as required by law or court order. e. Client agrees that Aon may disclose that Client and/or Affiliates are participants in an applicable survey. Survey participant lists may show general company information specific to Client/Affiliates, including some or all personal lives of the following: (i) company name; (ii) industry;data subject.