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Care2 Inc. Swiss – U.S. Data Transfer Policy

Care2 relies on the 2021 Standard Contractual Clauses (SCCs) as the primary legal mechanism for international data transfers in compliance with the GDPR and other applicable laws.

Care2 respects individual privacy and values the confidence of its users, customers, employees, business partners and others. Not only does Care2 strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, it also has a tradition of upholding the highest ethical standards in its business practices. This Swiss – U.S. Data Transfer Policy (the "Policy") sets forth the privacy principles that Care2 follows with respect to transfers of personal information from Switzerland to the United States.

Care2 is committed to keeping your personal information safe and secure and we have appropriate and proportionate security policies and organisational and technical measures in place to help protect your information.

This includes corporate policies and staff training regarding how your personal information should be handled, as well as physical security, encryption, and network security for IT infrastructure. Your personal information is only accessible by appropriately trained staff.

This Notice addresses data subjects residing in Switzerland whose data we may receive from one of our customers, suppliers or other business partners in Switzerland, e.g., referral partners, integration partners, etc. When Care2 receives client personal information for processing pursuant to instructions of clients or their partners, we are acting as an agent for our client and do not provide notice to individuals regarding the collection and use of their personal information. Our clients remain responsible for providing notice, if and to the extent they believe such notice is necessary under applicable Swiss law.

Business Purposes for the Collection and Use of Personal Information

Care2 allows individuals around the world to create and sign petitions on topics of public interest. As part of that signing process, we collect personal name and address information to validate the identity of the signer. Our treatment of that information is described here.

As part of the petition signing process, individuals may be offered opportunities to provide their information to receive ongoing communications from our clients.

Our Swiss clients may provide us with lists of email addresses or phone numbers of their existing members, encrypted with one-way hashes, to ensure that Care2 does not present signup opportunities to their existing members. As Swiss Data covered by this Policy is by definition sent to us by another company in Switzerland (e.g., a client of Care2), the client functions as the Data Controller and Care2 as the Data Processor in these cases. Care2 will not use client personal information for any other purposes than for the purposes that Care2 clients provide such information.

Care2 collects and uses Swiss Data for purposes of providing products and services to our users, communicating with petition targets, and processing Swiss Data on behalf of clients, and conducting related tasks for legitimate business purposes.

Regulations and Compliance

Care2 relies on the 2021 Standard Contractual Clauses (SCCs) as the primary legal mechanism for international data transfers in compliance with the GDPR and other applicable laws.

User Choice & Limits on Sharing

Care2 shares personal information with its service providers and among Care2's affiliates. With respect to the personal information we share with third parties, we provide our users with an opportunity to opt-out of such sharing. Contact Care2's Privacy Officer (address below) if you would like to opt-out. We do not use personal information for purposes incompatible with the purposes for which the information was originally collected without notifying the relevant consumers, customers, suppliers and others of such uses and offering an opportunity to opt-out.

In addition, we may disclose personal information (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials based on an enforceable government request or as may be required under applicable law, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity.

With respect to emails, Swiss Persons may opt-out of receiving further email communications from Care2 or Care2 clients by following opt-out or "unsubscribe" instructions contained within the email message in question.

Personal Information Access, Review & Update

Users can view, edit, revise, and delete most of the personal information stored by Care2 via the Care2.com website's self-serve "member profile" tools, available after logging in to the Care2.com website.

Accountability of Onward Transfer

Compelled Disclosure

Care2 may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Contact information and client personal information is accessible only by those Care2 employees and consultants who have a reasonable need to access such information in order for us to fulfill contractual, legal and professional obligations. All of our employees and consultants have entered into strict confidentiality agreements, and/or have been subjected to thorough criminal background checks requiring that they maintain the confidentiality of client personal information.

Swiss-U.S. Policy Update Date: June 1, 2026

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