Your privacy is important to us. This Online Privacy Policy explains how we collect, share, use, and protect information when you visit or use our Electronic Services, and any other online services offered by Safra National Bank and its affiliates Safra Securities LLC, J. Safra Asset Management Ltd. and J. Safra Inc (collectively “Safra”) that link to or reference this policy (collectively, our “Electronic Services or E-Services”). It also describes how Safra manage personal information about you when you interact with us online through our websites, mobile applications and social networking sites (“Sites and Mobile Apps”) through your computer, smartphone, tablet or other mobile devices (“computer or mobile devices”). By using our E-Services, Sites and Mobile Apps, you agree to the terms and conditions of this Policy. The term “Safra” or “we”, “us” or “our” in this Policy refers to affiliates of Safra National Bank and its affiliates that link to or reference this Policy.

This Policy explains

• How we collect personal information when you visit, use or interact with us online, and through our ads displayed through online services operated by us or non-affiliated third parties.

• How we may use or share personal information collected to deliver products and services to you and for advertising or event management purposes.

Updates to this Policy

This Policy is subject to change. It is updated periodically to comply with the most recent federal and local laws. Please review it whenever you have questions. If we make changes to this Policy, we will revise the Last updated date on this page.

Our Privacy Practices for Protecting Your Information

We are committed to transparency about your personal information. We ask for your consent when required, otherwise by using our E-Services, Site and Mobile Apps, you consent to the collection, use and sharing of your personal information subject to and consistent with applicable laws, regulations and other notices you may have received based on your relationship with us.

Providing Links to other sites

We may provide links to non-affiliated third-party sites, such as service providers or merchants. If you follow links to sites not affiliated with, or controlled by Safra, you should review their privacy and security policies and other terms and conditions, as they may be different from those of our Sites and Mobile Apps. Safra does not guarantee and is not responsible for the privacy or security of these sites, including the accuracy, completeness or reliability of their information.

Protecting your personal information

To protect personal information from unauthorized access and use, we use security measures that comply with applicable federal and state laws. These measures may include device safeguards and secured files and buildings as well as oversight of our third-party providers to ensure personal information remains confidential and secure. In the event of a data breach, we provide timely notification, in accordance with applicable laws and regulations.

Children’s Privacy

We recognize the importance of protecting privacy where children are involved. Our Electronic Services, Sites and Mobile Apps are not marketed to individuals under the age of 13. Accounts that include online access for children under the age of 13 are owned by a parent or guardian and require specific consent for online access. We do not knowingly collect personal information from children under 13 without prior parental consent.

Ensuring your personal information is accurate

Keeping your personal information accurate and up to date is very important. If your personal information is incomplete, inaccurate or not current, please use the Contact Us option on our Sites and Mobile Apps, or call your Account Officer, or contact our Customer Service team at 1-800-391-9195 (customer.service@safra.com regarding changes listed on your account statements, records, online or other account materials.

California residents covered by the California Consumer Privacy Act may have additional rights. Refer to our CCPA Notice for additional information.

Personal Information We Collect or Obtain

We collect personal information about you through your computer or mobile devices by the use of cookies and similar tracking technologies as well as personal information you provide when you interact with our E-Services, Sites and Mobile Apps, including when you apply for a loan or open an account; register for or request information about E-Services; use our websites or third party data sharing services. The personal information we collect is limited to what is required to provide you with our Services and to support legal and risk requirements. The types of personal information we collect from and about you online will depend on how you interact with us, and may include:

• Contact information such as name, mailing address, email address, telephone and mobile number(s).

• Account Application information such as credit and income information.

• Identifiers such as social security number, account number(s), driver’s license number (or comparable) or other information that identifies you for ordinary business purposes.

• Access authorization such as user ID, password and security codes.

• Documents or images submitted via our Sites or Mobile Apps to support account opening, such as statements and authorizations.

• Debit/Credit Card Information such as card number, expiration date, CVV2, billing address.

• Limited location information, such as unique device identifiers (for example Media Access Control (MAC) and Internet Protocol (IP) addresses); browser type, version, and display/screen settings; information about how you use and interact with our Sites and Mobile Apps (for example, activities on pages visited, links clicked or unique and measurable patterns such as keystrokes, mouse clicks and movements, swipes and gestures); communications data, such as your communication preferences and details or the content of your communications with us (e.g., text messages, chat messages); responses to advertisements on Sites and mobile apps where we advertise; log information such as your search and search engine referrals; geolocation information (for example, for real time ATM or location, upon request, or for fraud prevention); social media preference.

How We Use and Share Your Personal Information

Uses of your personal information: Personal information collected from and about you described in this Policy may be used for many purposes such as:

• Delivering products and services to you by verifying your identity (for example when you access your account information to process applications for Electronic Services).

• Detecting and preventing fraud, identify theft and other risks to you or Safra.

• Performing analytics concerning your use of our Electronic Services, including your responses to our emails and the pages or advertisements you view.

• Complying with and enforcing applicable legal requirements, industry standards, contractual obligations and our policies.

Mobile Application information: For your convenience, you have the ability to access some of our E-Services through mobile applications and mobile-optimized website. When you interact with us through your mobile app, we may collect information such as unique device identifiers for your mobile device, your screen resolution and other device settings, information about your location, and analytical information about how you use your mobile device. We may ask your permission before collecting certain information such as precise geo-location information.

Sharing your personal information: We may share the personal information we collect from and about you described in this Policy (and subject to other legal restrictions and notices you may have received depending on your relationship with us) with:

• Affiliates and subsidiaries of Safra National Bank of New York, such as: Safra Securities, J. Safra Asset Management, and J. Safra Inc.

• Third-party providers who have contracts with Safra.

• Government agencies as required by laws and regulations.

The personal information we collect is limited to what is required to provide our products or services and to support legal and risk requirements. Additional notice regarding the disclosure of information also includes our Privacy Notice.

Your choices

We offer certain choices in connection with the personal information we collect from you. You may update certain aspects of your account details and setting by logging and updating your preferences or limit the communications you receive from us. You can also unsubscribe from our marketing mailing list by following the “Unsubscribe” link in our emails, or email unsubscribe@safra.com . Safra does not share with non-affiliates or with joint marketing partners. Where appropriate requirements apply, we will limit sharing of your personal information based on your marketing and information sharing choices. Refer to our CA Privacy Choice.

Additional Information on Data Sharing

Third-party Data Sharing

Some companies may offer aggregation websites and services that allow you to share your data with them in order to consolidate your account information from different sources (such as your accounts with us or with other financial institutions), so that you can view it in one location or perform actions related to your accounts using their services. To do this, a third party may request you to authorize access to your Safra accounts by providing your Safra user ID and password or by providing your information-sharing consent directly to us.

• The third party may access, on your behalf, information about you, your account relationship, and your accounts with Safra. You should use caution and ensure that the third party has appropriate policies and practices to protect the privacy and security of any personal information you provide or to which they are gaining access.

• Use of your information by the third party is governed by your agreement with them, not by Safra. We recommend reviewing the third party’s policies before sharing your personal information to understand how they will use and store your account information. For example, look for whether they sell any of your personal information, and if your information will be transferred, processed, or stored outside of the United States.

• We are not responsible for the use or disclosure of any personal information accessed by any company or person to whom you provide your site user ID and password.

• If you share your Safra user ID, password or other information about your accounts with others, we will consider that you have authorized any transaction or action initiated by using the access information you provide.

You may revoke your consent for certain third parties by contacting your Account Officer or our Customer Service team at 1-800-391-9195 (customer.service@safra.com). If you decide to revoke the authority you have given to a third party, we strongly recommend that you change your Safra password to ensure that the third party cannot continue to access your account.

Social Media

Safra may engage with customers on social media platforms such as Facebook®, X®, Vimeo®, Instagram®, YouTube® and LinkedIn®. Please note the following:

• Any content you post on the social media ages managed by Safra, such as pictures, information, opinions or any personal information that you make available to other participants on these social platforms, is subject to the Terms of Use and Privacy Policies of those respective platforms.

• When interacting with social media pages managed by Safra, our Privacy Notice, and other terms and conditions may apply.

• Please review the privacy policy for the specific social media service you are using to better understand your rights and obligations with regard to such content.

Cookies and Data Collection

What are Cookies

We may also collect information through cookies, tags, and other technologies. Cookies are small text files that your browser stores on your computer or mobile device when you visit a site. When you return to a site you have visited before, your browser gives this data back to the site to help it remember your preferences and personalize your experience; enhance site performance and security; and enable interest-based advertising. When you visit our Sites, we, or our service providers, may use cookies or other similar technologies to collect information on our Sites.

How we use Cookies

We use cookies and information collected through their use to make your experience with us and other sites more personalized based on the products, services, or other interactions you have with us. Information collected through use of cookies may be used to provide you with information about our products and services, for purposes such as maintaining continuity during an online session, collecting data about the use of our Sites, monitoring online promotions, and anti-fraud and information security purposes.

Other parties that may collect information about your web browsing behavior when you use our Sites are generally limited to service providers who may only use any information collected to provide services. However, we may also provide certain links on our Sites that allow you to interact with third parties who offer additional features, such as allowing web surfers to share information on another platform, such as a social media platform. These features often function through the use of third-party cookies utilized by the third-party site, such as a social media platform. As a result, if you use any of these features, these third parties may be able to access information about your web browsing on the pages of our Sites where links to these features are in place. You may wish to review information at third party sites, such as social media platforms where you have an account, to determine how these third parties treat data that they obtain with the use of cookies.

Types of Cookies we Use

We may use cookies that expire at the end of a web browsing session when you close your browser (session cookies). These cookies help the site remember your actions during the current website visit. Some cookies may remain stored on your device between browsing sessions until a pre-set expiration period determined by us or our service providers (persistent cookies). These types of cookies allow us to improve website experiences and place advertisements. There are four categories of cookies we may use on our Sites:

• Strictly necessary: These cookies are necessary for our Sites to function or to enable functionality requested by you. They’re needed to do things like securely signing on to our Sites or obtaining a product or service. You can set your browser to block all cookies, but some parts of our Sites won't work without them.

• Functional: These cookies enable an enhanced or personalized experience. This may include things like playing videos on our Sites or downloading PDF forms or seeing content personalized to you. If these cookies are blocked, then some of these services may not function.

• Performance and analytical: These cookies allow us to monitor the performance of our website, such as how many people are visiting our Sites and how they got there, so we can measure and improve your experience on our Sites. If these are blocked, we have less information available to us to continue to improve our Sites.

• Marketing and advertising: These cookies may be set by us or through our advertising partners. This information is used to understand your use of our Sites so we may show you more relevant online content and advertising. If you block or turn them off, you may still see online advertisements, but they won’t be tailored to you based on your browsing behavior.

Managing Cookies

Most browsers are initially set to accept cookies. However, you have the ability to disable cookies if you wish, generally through changing your internet software browsing settings. It may also be possible to configure your browser settings to enable acceptance of specific cookies or to notify you each time a new cookie is about to be stored on your computer enabling you to decide whether to accept or reject the cookie. To manage your use of cookies there are various resources available to you, for example the “Help” section on your browser may assist you. You can also disable or delete the stored data used by technology similar to cookies, such as Local Shared Objects or Flash cookies, by managing your browser’s “add-on settings” or visiting the website of its manufacturer. As our cookies allow you to access some of our website’s features, we recommend that you leave cookies enabled. Otherwise, if cookies are disabled, it may mean that you experience reduced functionality or will be prevented from using the site altogether.

Record Retention

We retain personal information for a period of time as required by laws and regulations and the necessary business purpose. For instance, we may retain your information during the time in which you have an account to use our websites or E-Services and for a reasonable period afterward. We also may retain your information during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements. When we no longer require your personal information, we will take reasonable steps to securely delete, destroy or de-identify it your personal information as soon as legally permitted.