on the HUNT for the Next DIAMOND in the ROUGH
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$TSNP #HUMBL ONCE IN A LIFETIME DO YOU COME ACROSS OPPORTUNITIES LIKE THIS!!!
$TSNP #HUMBLThey researched and studied ALIBABA to build their platform upon
$TSNP WORLD CLASS #HUMBL TEAM Wow Who Isn't EXCITED!!!!? Read through this carefully!!!
HUMBL is comprised of a diverse set of founders, consultants and advisors with experience at Western Union, Moneygram, American Express, Visa, Facebook, Microsoft, Epson and Qualcomm.
Brian Foote
Chief Executive Officer, President
Brian Foote is the founder of HUMBL and leads the daily operations of the company. Brian brings with him twenty years of consumer technology experience, having launched a number of top ranked global technology products across brand, market research, strategy and channel sales at companies like EPSON, where he was twice named to the CEO Innovators Award for his cross-functional work on consumer technology lineups that went to #1 in the world in sales in their respective categories.
Brian is a former Sr. Vice President of a consulting firm in Silicon Valley, and has worked with Fortune 500 clients and merchants like Amazon, Best Buy, Costco, Walmart and Target to drive channel and merchant product sales, which led him to develop his market research around HUMBL and HUMBL Hubs consumer and merchant software products in the emerging markets.
Brian performed his education at University of Pennsylvania (PENN), where he was named an All-Ivy League athlete. He then transferred to University of California at Los Angeles (UCLA) where he completed his degree and was on an NCAA Final Four soccer team. Brian holds certifications in blockchain payments, digital and social media at Massachusetts Institute of Technology (MIT).
Brian was recently featured in Forbes as the CEO of a Startup to Watch in 2020 and as a featured speaker surrounding the positive impact of HUMBL digital payments, cross-border remittance and lending on Asia Pacific and Oceania Region on Government Programs and National GDP’s in conjunction with the UN 2030 Agenda.
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Jeff Hinshaw
Chief Operating Officer, Corporate Secretary
Jeff implements the daily financial and operations components of the HUMBL business, working with internal team members and external law firms, accounting firms, compliance and consultants.
Jeff brings hybrid academic and business experience to the role at HUMBL, having worked in finance, corporate planning, strategy and operations roles at Hewlett Packard (Nasdaq: HP) and Sempra Energy (NYSE: SRE).
Jeff has served as a guest lecturer at San Diego State University, where he was involved in their Entrepreneurship Program and served on the SDSU Endowment Fund investment group.
Jeff was an investor in previous successful startups in the nutrition and fitness industries and holds several publishing credits in scientific journals.
Jeff graduated undergraduate from University of California at Santa Barbara (UCSB) in Business Economics and received his MBA in Finance from San Diego State University (SDSU)
Adam Wolfe
Chief Technology Officer
Adam Wolfe leads the technology deliverables of the HUMBL mobile wallet application and HUMBL Hubs merchant and agent software programs across multiple borders, currencies and exchange partners, bringing over a decade of experience as both a traditional FinTech, payments and blockchain engineer.
Adam is a specialist in Cross-Platform Mobile Applications, Web Development, Java Script, Angular and serverless Payment Cloud architectures that are required for HUMBL and HUMBL Hubs innovative and patent-pending mobile technology and software lineup.
Adam manages both HUMBL’s internal technology developer suite and external agency teams, as well as third party integration partners. His technology background previously was in hybrid Information Technology and engineering roles at Qualcomm (Nasdaq: QCOM) and PowerFleet (Nasdaq: PWFL).
Michele Rivera
VP, Global Partners
Michele drives HUMBL channel partner sales and HUMBL Hubs merchant software sales into global retail environments. As HUMBL channel sales and partners lead, Michele has developed robust partnerships on behalf of HUMBL with internal global technology partners, external strategic partners and new business clients in core verticals such as Latin America banking and retail merchant services.
Michele worked in merchant retail environments with Williams Sonoma (NYSE: WSM), where she managed over 100 interdisciplinary staff across sales, training, delivery, supply chain and logistics and performed National Sales Training on behalf of the company across North America.
Michele performed her Corporate Training at the Disney (NYSE: DIS) corporation headquarters, working across a variety of roles in retail environments.
Michele was recently featured in Forbes as a Female Co-Founder of a Rising Startup to Watch in 2020
Karen Garcia
VP, Major Accounts
Karen drives HUMBL channel partner sales and HUMBL Hubs merchant software sales into global retail environments. As HUMBL partners lead, Karen has developed robust partnerships on behalf of HUMBL with internal global technology partners, external strategic partners and new business clients in core verticals such as Latin America banking and retail.
Karen worked in merchant retail environments with Williams Sonoma (NYSE: WSM), where she managed over 100 interdisciplinary staff across sales, training, delivery, supply chain and logistics.
She received her corporate training at Nordstrom (JWN: NYSE) corporation headquarters, working across a variety of roles and has also worked in corporate at L Brands (NYSE: LB) and Eddie Bauer in areas such as merchant sales and purchasing.
Karen was recently featured in Forbes as a Female Co-Founder of a Rising Startup to Watch in 2020.
Mario Vargas
Global Payments and Financial Services - Latin America
Mario helps to drive HUMBL and HUMBL Hubs penetration of Latin America, Caribbean, Asia Pacific and Africa markets across key vertical markets of governments, merchants, wireless and banks.
Mario is a 20 year veteran of mobile payments and financial services with Western Union, Walmart and Fiserv, with an emphasis on financial services, wire services and bill payments in the emerging markets.
At Western Union, he partnered with global banks and money operators in Africa, Europe, Asia and Americas to help drive the Western Union to over 500,000 merchant-agent locations and will be helping advise on the HUMBL Hubs rollout into underserved regions.
Ayo Popoola
Global Payments and Financial Services - Caribbean and Africa
Ayo leads HUMBL sales and partnerships in Africa, Caribbean and Latin America, through key vertical markets such as government, wireless carriers, banking and merchant services. Ayo previously worked as a Global Consultant with over 20 years-experience in various industries from Payment Processing, Mobile, Satellites, GPS, WiFi, Data -Payments, Banking and third party integrations strategies. Ayo has lead global teams in Latin America, Africa and Europe for Nokia Brazil, Procter and Gamble and the Belgian Government.
Rajan Narayan
Global Payments and Financial Services - Asia Pacific and Oceania
Rajan has over 30 years of experience in established and startup payment corridors in Financial Technology. He spent from 1995-2000 as a VP of ACI Worldwide. He is now the CEO of Cyberbeat, as a formal payment partner of Visa, American Express and Mastercard.
Rajan is a consultant to government, wireless and merchant processing partners across the Asia Pacific region as well as a consultant to digital payment migration clients such as the governments of Singapore, Nepal and India.
Rob Ayers
Global Payments and Financial Services - North America
Rob brings 30 years of experience in financial technology, credit cards and banking to HUMBL and HUMBL Hubs across special projects in FBObanking, financial services and payments, with an emphasis on the North America markets.
Rob began his career at American Express, where he became Global Director of Sales and Marketing. Rob then moved to Moneygram, where he served as an Executive and Advisory Board member.
Rob has consulted with a variety of fintech startups on their path to getting acquired or going public.
Zach Stevens
Design and Branding Lead
Zach Stevens is a veteran designer with experience in branding, website design, user experience and marketing.
He brings a design-thinking approach to the creation of new software and product initiatives on the HUMBL Team.
Zach received his BFA from San Diego State University where he was the Lead Designer at the Lavin Entrepreneurship Center and has worked with several Southern California startups
Dixit Patel
Lead Technology Developer
Dixit has served as a Lead Developer for Costco, helping integrate their back-end systems and merchant POS systems – across US, Canada, Mexico and Europe. He is a highly skilled full stack developer with experience with Java, Laravel, Angular, React Native, and Firebase.
Alexander Gill
Technology Developer
Alex is a full stack developer working on the HUMBL mobile wallet and HUMBL Hubs merchant software, bringing vital experience in mobile and web software from the banking and retail sectors.
He brings valuable merchant retail experience with Target in their mobile, website and point-of-sale (POS) systems.
He has also developed for Santander Bank on their payment and merchant services software systems and hardware integration.
Kimberly Solano
Technology Developer
Kimberley is experienced in platform integration and improvements analysis; knowledge in APIs, Agile and JIRA; high orientation to quality results, great ability to prioritize and ease complex situation analysis.
Western Union – Accomplishments:
•Support over 200 countries providing daily maintenance for the global platform, receiving request through JIRA ticket tool, providing ETA and proposing process alternatives.
•Design, implement and website and digital products for Latin-American and Caribe countries.
•Over 20 global websites were migrated to the new responsible mobile friendly platform to improve usability and accessibility.
•Product Owner for Stage & Pay and API integrations
Barbara Gonzalez
HUMBL Hubs - Merchant Software
Barbara is helping with the systems design of the HUMBL Mobile Wallet and HUMBL Hubs Merchant software in regards to HUMBL customer experience, merchant and agents in the field.
She is responsible for the database administration process and support of Western Union agents in Latin America, Caribbean, Africa, Middle East, Asia and Oceania as well as leading the agent support team for Latin America and Australian agents.
Barbara is dedicated to agent relations and operational coordination support and was the business contact person for agent network within Central and South America including Cuba and Dominican Republic.
She is comfortable with both the HUMBL online and off-line customer and agent support of transactional and operational inquiries for agents in Mexico, Central and South America, the Caribbean, Europe, Africa and Middle East.
Marcela Quesada
HUMBL Hubs - Merchant Software
Liaison between product/business team and customer service center for supporting activations of new corridors or products. Business process management, credit card authorizations, subject matter expert on international agent training and team leader for 24/7customer support.
Western Union – Accomplishments:
Process improvement and documentation
•Standard Operating Procedure (SOP) template creation
•Customer Service Representatives (CSRs) supervision
•Agent support (English, Portuguese and Spanish)
•Support service migration process
•Expertise in Standard Operating Procedure (SOP) documentation and template creation
•Experience in Policy documentation
•Experience in providing virtual training video conferences
David Nhim
Sr. Technology Consultant
David brings senior technology advisory experience to the HUMBL and HUMBL Hubs global payments and transfer network. David works for the Ticketmaster network, which delivers, trading, transfer and payment of over 100 million tickers a quarter. David has led teams in Data Warehousing and Business Intelligence for several years and has extensive experience in data modeling, ETL development, and database administration. He has worked with proprietary tools like Business Objects, Microstrategy, and IBM Data Stage, as well as Open Source tools like Pentaho BI Suite (Reporting and ETL) and Talend Open Studio.
Noah Seidman
Sr. Technology Consultant
Noah Seidman provides valuable technology advice on the HUMBL Mobile Wallet and HUMBL Hubs Merchant software architecture. Noah currently works at Facebook as Lead Developer and has previously worked for Microsoft as a Lead Developer. For the last 8 years Noah has managed teams of Android developers, ranging in size from 2 - 8 developers, using Agile methodologies. Noah has managed offshore teams, implemented strategic and collaborative code review processes, all while ensuring the implementation of a robust and modern coding architecture. Noah is responsible for designing the fundamental architecture of programs and has experience in multiple blockchain projects like REN and Digibyte. His favored architecture is MVVM with data bindings using a Multi Type Data Bound Adapter pattern.
Mark Turner
Corporate Advisor - Global Networks and Cybersecurity
Mark Turner provides valued advice to the HUMBL Payments Network as a global network, cybersecurity and encryption advisor. Mark lead Qualcomm’s Cybersecurity division for over 14 years and currently is the Director of Security Engineering at ViaSat, a leader in air, land and sea communications.
Mark is a proven leader in global technical leadership and management, along with hands on technical experience in: cybersecurity, risk management, security software development, security architecture, and DevOps for Fortune 500 and global telecommunication leading companies.
Mark currently holds CISSP, CRISC and AWS Certified Solution Architect certifications. Along with a BS in Computer Engineering from San Diego State University (SDSU) and a master’s in architecture-based Enterprise System Engineering from University of California San Diego (UCSD).
George Sharp
Corporate Advisor - Capital Markets and OTC Compliance
Well-known exposer of OTC fraud. Advisor to public companies & SEC attorneys. Former consultant to OTC Markets Group.
https://twitter.com/GeorgeASharp
Adrian J Romero
Corporate Advisor - Latin America Markets
CEO of Grupo Consultor, growing the business from two employees to 250 in under 5 years. He will provide due diligence and system-wide expansion across Latin America for HUMBL.
Brian Innes
General Counsel
Brian Innes is a partner at Hansen Black Anderson Ashcraft. Mr. Innes advises clients with respect to public and private securities offerings, venture capital and angel investor financings, mergers and acquisitions, initial coin offerings (ICOs), cryptocurrency, blockchain and distributed ledger technology, private equity transactions, business formations, technology licensing, commercial contracts, general securities law compliance, and securities litigation.
PROFESSIONAL EXPERIENCE AND MEMBERSHIPS
Associate, Carman Lehnhof Israelsen LLP, 2010 – 2012
Associate, Stoel Rives LLP, 2007 – 2010
Assistant Honorary Consul of Finland for Utah, Idaho, Montana and Wyoming, 2010 – Present
Member, Utah State Bar Securities Law Section
Member, Utah State Bar Business Law Section
EDUCATION
University of Utah, S.J. Quinney College of Law (J.D., 2007, with high honors)
Articles Editor, Utah Law Review
William H. Leary Scholar
Utah State University (B.S., Finance, 2004, cum laude)
Economics (Minor, 2004)
Member of Phi Kappa Phi National Honor Society
Member of Beta Gamma Sigma National Honor Society
PROFESSIONAL HONORS AND ACTIVITIES
Named to Utah’s Legal Elite by Utah Business Magazine
?Named a Rising Star by Super Lawyers Magazine
PRESENTATIONS
“Crypotcurrency Laws and Regulations: What You Need to Know” Utah Bitcoin Community, Salt Lake City Library, Salt Lake City, Utah.
"Show Me The Money: The Fundamentals of Raising Capital" Entrepreneur's Law School, Salt Lake Small Business Development Center, Salt Lake City, Utah.
"Blockchain and the Law" Utah Blockchain Meetup Group, The Startup Building, Provo, Utah.
“Blockchains, Cryptocurrencies and Why They Matter” The Insiders Fund Dare to Perform Summit, Hotel Park City, Park City, Utah.
PERSONAL
Proficient in Finnish
Interests include basketball, softball, golf and reading
http://www.hbaalaw.com/brian-r-innes.html
Jim Broder
Patent Attorney
https://www.linkedin.com/in/jim-broder-0050ab5/
Pollie Gautsch
Trademark Attorney
Pollie Gautsch is a California licensed attorney with extensive experience in corporate legal work. She began her career as a trademark specialist at an international intellectual property law firm and transitioned into Akkadix Corporation, a La Jolla based agricultural biotech company as a Corporate Counsel specializing in intellectual property, employment and corporate governance. Ms Gautsch continued her career advancements by becoming a Senior Corporate Counsel for The Upper Deck Company, LLC, a large sports and entertainment publishing company.
As Senior Corporate Counsel, she headed the company’s fraud investigation team protecting valuable brands; managed the intellectual property group, handling the company’s over 2,500 trademarks and its large patent and copyright portfolio. Additional she also negotiated and drafted license agreements with licensors including Disney, Nickelodeon, Marvel and DC Comics, and advised all departments of the company with their legal needs including human resources, executive, operations, facilities, manufacturing, purchasing, finance, travel, and sports and entertainment licensing.
She is a member of the California and San Diego Bar Associations, International Trademark Association, The Lawyers Club, and the American Corporate Counsel Association.
https://www.linkedin.com/in/polliegautsch/
https://www.humblpay.com/humbl-team
Safe Harbor Statement
Copyright 2020 HUMBL
®
LLC
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$TSNP #HUMBL PRODUCTS
HUMBL is a mobile wallet that will help global consumers send, receive, exchange, borrow and invest money in new ways. No matter where they live.
HUMBL Hubs helps merchants in cash dependent countries migrate to the digital economy. We provide simple software solutions that allow merchants to deliver contactless payments, text to order and money services.
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https://www.humblpay.com/humbl-about-products
$TSNP #HUMBL A New Digital Way To Use Money
HUMBL will allow you to send, receive, exchange and borrow money at up to an estimated 50% savings vs. competitors.
Mobile Payments for Emerging Markets
HUMBL will be working in Latin America, Caribbean, Africa and the Asia Pacific in countries that have been overlooked or underserved by traditional payments and financial service providers.
Who We Serve
HUMBL works across banks, borders and currencies. The company will be focused on working with targeted verticals, such as: Governments, Wireless, Banks and Merchants with existing customer bases who are looking to go digital with their money.
Product Features
In regional markets like Latin America, Africa, Caribbean and the Asia Pacific, cash is still the predominant media for money. This can result in long lines, high fees and slow processing times. HUMBL and HUMBL Hubs SOLVE FOR THIS with digital, contactless and connected money services.
Borderless
Contactless
Connected
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Copyright 2020 HUMBL
®
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$TSNP #HUMBL Send Money
HUMBL allows you to split a bill or send money around the world in over 55 countries.
Request Money
HUMBL allows you to get paid in one click, from anywhere you are.
Exchange Money
HUMBL allows you to skip the line and instantly exchange money in over 60 currencies.
Bill Payments
HUMBL also delivers the best dynamic pricing on services like bill payments, cell minutes and loan applications.*
*Services vary by country and partners.
Get HUMBL
®
If you would like to see a demo,
please inquire below.
NAME
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Copyright HUMBL® 2020
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®
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https://www.humblpay.com/consumers/money-services
$TSNP #HUMBL Text Ordering
Seamless ordering and pickup from your favorite merchants.
Contactless Payments
Simple, touch-free payments from your smartphone.
Rate + Review
Find and interact with your favorite local merchants.
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®
If you would like to see a demo,
please inquire below.
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https://www.humblpay.com/consumers/mobile-payments
$TSNP #HUMBL MOBILE WALLET
Mobile Wallet
Send, request and exchange money around the world. Right from your smartphone.
Mobile Wallet
HUMBL is a consumer mobile app that accommodates all formats of digital money.
Manage Your Accounts
HUMBL allows you to store traditional bank accounts, credit cards and digital assets in one place on your smartphone.
Store Your Money
HUMBL will contain new products like US Dollar stablecoins, to help you protect your money against currency fluctuations.
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Copyright 2020 HUMBL
®
LLC
All rights reserved.
https://www.humblpay.com/
$TSNP #HUMBL MERCHANTS AGENTS
Agent Software
Level up your business with money service offerings to your customers.
Money Services
Drive higher foot traffic and additional income by helping your customers with basic money services.
Remittance Services
Help customers send, receive or exchange money.
Bill Payments
Help your customers pay bills and cell minutes.
Loan Services
Help customers apply for competitive rate loan products.
Get HUMBL
®
If you would like to see a demo,
please inquire below.
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®
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All rights reserved.
https://www.humblpay.com/merchants/agents
$TSNP #HUMBL Merchant Software
Rapidly migrate your business to the contactless, digital economy.
https://www.humblpay.com/merchants/home-copy
$TSNP #HUMBL Beyond The COVID-19 Crisis:
A Framework For Sustainable Government-To-Person Mobile Money Transfers
November 2, 2020
During the 2020 pandemic, the majority of countries have provided income support to households at an unprecedented speed and scale. Social distancing measures and the large penetration of mobile phones in emerging markets and developing economies (EMDEs) have encouraged government-to-person (G2P) transfers through mobile platforms.
https://www.humblpay.com/network/research
$TSNP #HUMBL NETWORK OVERVIEW
The fast way to send money from the United States to Latin America, Asia and Oceania #HUMBL allows you to transfer money across borders the same day and for low, transparent fees and exchange rates. You cannot currently use HUMBL if you live in Hawaii, Wyoming, New York, Oregon, North Dakota, South Dakota, Vermont, New Hampshire, Connecticut, Virginia or North Carolina.
The fast way to send money from the United States to Latin America, Asia and Oceania
https://www.humblpay.com/network/overview
$TSNP #HUMBL BRAND VIDEOS (SPANISH & ENGISH VERSIONS)
https://www.humblpay.com/media/brand-video
$TSNP #HUMBL PRODUCT TOURS
https://www.humblpay.com/media/product-tours
$TSNP #HUMBL Cybersecurity Statement
General
Firms have an obligation to assess and prioritize risks associated with their information technology systems. Accordingly, HUMBL (“the Company”) has established these protocols that describe the approach to protect data and preventing threats to data.
The Cybersecurity Policy must be approved in writing by the Firm’s CEO, CIO, CTO or other senior leader.
Employees are informed of the cybersecurity policy upon hiring and on an ongoing basis.
The Company will conduct an annual review of the Cybersecurity Policy, which may include penetration tests of the firm’s systems as a best practice.
No employees are permitted to install software on firm-owned equipment without first obtaining written approval from the IT Department (“IT”). The Company has implemented security procedures to protect nonpublic personal information that is electronically stored or transmitted include authentication protocols, secure access control measures, and encryption of all transmitted files. The Company has adopted procedures to promptly eliminate access to all Company networks, devices and resources as part of its HR procedures in the event an employee resigns or is terminated. Such an employee must immediately return all firm-related equipment and information to the CTO or head of HR.
Protected Information
The Company may, in the course of employment or business, collect, develop or maintain specific information or documentation about individuals or entities that may be deemed to be personally identifying information (“PII”) or confidential and proprietary in nature ("Confidential Information") (jointly, "Protected Information”). For purposes of this policy, examples of PII include a person’s bank account number and social security number, among other types of information. Examples of Confidential Information may include an entity’s bank account number, financial statements, investment advisory agreement, and investment management agreement, among other types of information.
Access Controls
General
The confidentiality and integrity of information and data stored on Company information systems, including but not limited to Protected Information, is protected by access controls to ensure that only authorized persons have access. The Company and physical access controls are designed to prevent destruction or corruption of the Firm’s information systems and data, as detailed below.
The Company will:
Protect its physical facility against unauthorized intrusion by imposing appropriate restrictions on access to the facility and protections against the theft of equipment;
Establish appropriate identity and access controls to its systems and data, including media upon which information is stored;
Require employees to use complex passwords and changing them periodically;
Use and maintain up-to-date firewall and anti-virus and anti-malware software to protect against threats posed by hackers;
Use supported and trusted software or, alternatively, implement appropriate controls regarding the use of unsupported software;
Use automatic software updating functionality or, alternatively, manually monitor the availability of software updates and install updates, and spot checking to ensure that updates are applied when necessary;
Use supported and current operating systems or, alternatively, implementing appropriate controls regarding the use of unsupported operating systems;
Regularly backup systems and data as part of a sustainable disaster recovery and business continuity plan;
Use network segmentation and network access controls;
Use secure software development practices if the Company develops its own software; and
Ensure that mobile devices are subject to similar applicable safeguards.
System Access
It is prohibited for any person to intentionally access any Protected Information on Company information systems that are not relevant to such person’s job duties.
Access to the Company’s information systems is limited to authorized persons and only to those parts of its systems that are appropriate to each employee’s, consultant’s or vendor’s job duties. Employees, consultants and vendors should not attempt to access another person’s computer account without the prior consent of such person or of his or her supervisor. Function heads and supervisors should notify the IT Service Desk promptly whenever an employee leaves the Company, a consultant or vendor relationship is terminated, or other circumstances exist that require additional or restricted access to the Company’s information systems so that such person’s access can be appropriately changed or revoked.
Passwords must be strong, such as those containing combinations of lower case letters, upper case letters, and numbers or symbols and cannot be passwords that might be easily guessed like birthdays or commonly-used strings like "password" or "12345." Employees must never share their passwords or store them in a place accessible to others. Employees must shut down or lock their computers when they leave the office for any extended period of time. Employees are required to change passwords on a periodic and regular basis.
Physical Access
The Company will maintain building security standards, including card access requirements. Servers are stored in secured room or remote location with access restricted to authorized personnel. Hard copy documents containing PII may be stored in lockable filing cabinets, which shall be kept locked, except where attended by employees with a business need for regular access to such information. Documents containing Protected Information must never be left unattended in public spaces, such as copying rooms, conference rooms, or lobbies. When the Company is not required to retain hard copy documents containing Confidential Information, the hard copies should be securely disposed by shredding the documents or placing them in a secure receptacle for subsequent shredding and secure disposal.
Security and Risk Analysis
The Company will conduct an assessment of systems on a periodic basis. During such assessment, the Company will:
identify and assess threats, vulnerabilities, and “at risk” data (such as customer and counterparty personally identifiable information, to extent the Company possesses that information);
assess threats and vulnerabilities to its electronic infrastructure, including systems used to initiate, authorize, record, process, and report transactions relating to customer funds (to the extent the Company possesses that information), capital compliance, and risk management;
incorporate past internal and external security incidents that the Company has experienced and consider known threats that have been identified by third parties (such as the industry and the Company’s critical third-party service providers, among others); and
estimate the severity of potential threats, perform a vulnerability analysis, and consider modifying the framework for managing risks of cybersecurity threats to the Company based on the results of periodic testing. Examples of potential threats include viruses, spyware, or malware; loss, destruction, or theft of critical hardware that contains at-risk data; and interception of (or other compromise) to email, payment processing systems, or other electronic transmissions.
Third-Party Service Providers
With respect to critical third-party service providers—such as cloud-based services or service providers that operate outsourced systems for the Company—the Company’s assessment will address risks posed by such service providers. The Company will identify and when appropriate avoid using service providers whose security standards are not comparable with the Company’s standards.
When the service provider no longer performs services for the Company, the Company will restrict or terminate the service provider’s access to systems.
The Company will use the below chart to identify third party service providers and their cybersecurity policies and procedures relevant to protection of the Company or Protected Information:
Third-Party Service Provider and Date the Company Received the Information
Cybersecurity Policies and Procedures
Name, Date
The following items are examples of the feedback you should anticipate receiving from third-party service providers:
Name, Date
For a website host service provider, the following items are examples of cybersecurity policies relevant to protection of Protected Information:
They create every web site with the capability of password-protecting information as deemed necessary by the site’s owner. Every user ID and password has minimum requirements with regard to the configuration of the ID and password.
In the event of an incident in their systems, initial communications to the Company will be sent by their Information Security Officer (ISO) upon approval by the president and based on the severity of the incident. Ongoing communications to customers may be sent by a delegate of the ISO using a format and language approved by the ISO. Communication upon resolution and after post-incident activity shall be sent by the ISO or a delegate of the ISO using an approved format and based on the severity of the incident.
Name, Date
For a primary server provider, the following items are examples of cybersecurity policies relevant to protection of Protected Information:
They employ remote and server network monitoring, which includes the monitoring of CPU activity, disk and memory utilization, process execution, batch log, appended log and Windows event monitoring.
They use real time status reports with notification and multiple levels of escalation when a device reaches a warning or failure state.
Access to customer data is limited and based on an employee’s role.
Password access has additional log-in restriction requirements and is controlled by an encrypted password vault.
Pursuant to the primary server provider’s Incident Response Policy Summary, the phases of their incident response plan are described as follows:
During the detection & analysis phase, the source of the incident and the scope of its impact will be determined.
During the containment phase, the provider will seek to prevent the spread of any intrusion and limit its impact.
During the remediation phase, the provider will remove the intrusion from the network and provide notification to the Firm.
The recovery phase will involve the restoration of production services and hardening of the provider’s environment.
After the incident, the provider will analyze the intrusion and develop procedures to prevent future intrusions.
Name, Date
For a back-up server provider, the following items are examples of cybersecurity policies relevant to protection of Protected Information:
They employ several different mechanisms for monitoring their production environment, including automatic network scanning as new data is loaded, monthly vulnerability scans, and annual penetration testing.
They have defined procedures in their Information Security Policy to identify, report and respond to security breaches and security incidents within their systems.
Their Customer Service Portal provides various ways (including call, e-mail and chat) for its customers to report system security breaches and other incidents. Any such breaches or incidents are escalated to the proper personnel at the back-up server service provider based on the severity of the incident.
Incident Response Plan
The Company has established an incident response plan, attached hereto, to manage detected security events or incidents, analyze their impact, and mitigate their threat. The incident response plan is designed to coordinate responses both internally and externally.
Procedures employed in the event of specific, defined circumstances are outlined below.
Unauthorized Website Access – In the event that an unauthorized person gains access to a customer’s online account, IT will remove the customer’s website user ID from the site, remove all account data for the customer from the website, and notify the web server if the server is not aware of the breach.
Fraudulent Customer Communication – In the event that the Company receives a fraudulent communication purporting to be from a customer, the Company will escalate the issue to IT and the CTO. The Company will notify personnel and require that all account transfer requests related to the customer are verbally approved by calling the customer at a telephone number known to the Company. The Company’s CTO will contact the relevant custodian to notify the custodian of the fraudulent communication. The Company will contact the customer if the customer is not aware of the issue. Account information will be accessible through the phone only until the customer provides confirmation that electronic communication is permitted for the account.
Loss or Theft of Laptop or Mobile Device – In the event that an employee laptop or device is lost or stolen, IT will wipe all information from the lost device. An authorized person from the Company may contact outside counsel to discuss the situation and whether further steps are necessary.
Breach of Main Server – In the event of a breach of the main server, the Company will switch to the back-up server. IT will investigate the breach and determine how to contain the breach as quickly as possible. The Company will ensure that access is denied to anyone who attempts to log in to its website. An authorized person from the Company may contact outside counsel to discuss the situation and whether further steps are necessary.
Breach of Back-Up Server – In the event of a breach of the back-up server, the Company will shut down the back-up server. IT will investigate the breach and determine how to contain the breach as quickly as possible. The Company will ensure that access is denied to anyone who attempts to log in to its website. An authorized person from the Company may contact outside counsel to discuss the situation and whether further steps are necessary.
APPENDIX : DATA BREACH INCIDENT PLAN
Phase I: Determination of a Breach, Alert and Organization
Company alerted to possible data breach - record date, time, and method of alert
Notify relevant internal Incident Response Team (IRT), consisting of a representative from, as needed:
Information Technology
Legal/Compliance
HR
Public Relations
Customer Service
Business Head identifies an incident lead for this incident - performs as project manager
Coordinate or convene conference call of IRT if needed
Determine whether a breach has occurred. If a breach has not occurred, the remainder of this Appendix do not apply. However, a possible incident log will be maintained which includes the record date, time, and method of alert and basis for determination. The IT Contact will maintain the log.
If determined there is a breach, consider hiring forensic technology partner depending on available internal resources and complexity of breach
If determined there is a breach, notify insurance carrier/understand scope of preauthorization or limitations on third-party vendor reimbursement if needed.
Phase II: Initial Scoping Before Containing an Ongoing Breach
Identify, document, and preserve initial understanding of scope of compromise to the extent possible within 24-48 hours
Consider notifications or steps to take before stopping the breach that may prevent harm in the event the act of stopping the breach alerts data thieves that you have discovered them
Preserve any evidence related to the ongoing breach
Phase III: Contain the Breach
Be sure that the full scope of compromise is understood to the extent possible within 24-48 hours
Contain/arrest the breach — stop any possible flow of data to unauthorized recipients
Document results of containment effort
Phase IV: Conduct Investigation
Root cause analysis
Classify type of breach
Hacking
Internal
Loss/Theft of Tangible Data (computer, device, storage media)
Inadvertent Disclosure
Loss with No Known Disclosure
Other
Full identification of data compromised
Type of information compromised
Sensitive personal information
Social Security numbers
Credit card information
Financial account data
Medical information
Usernames and passwords
Driver’s license numbers
Other sensitive personal information (disclosure of which could cause harm)
Other personal information
Contact information (name, address, email address, phone number, etc.)
Preferences, purchase history
Other information linked to a person that is not sensitive
Individuals whose information was compromised, including where they reside
Determine nature of any unauthorized recipients
Employee acquisition in good faith
Business partner
Trustworthy recipient who normally receives information of this nature
Unknown individuals, but definite disclosure
Lost information — may not have been disclosed
Suspected bad actor/employee not in good faith
Known bad actor/departed or departing employee
Assess known or discoverable actual use of compromised information
Undertake security updates necessary before notification
Phase V: Notifications (In light of information developed in Phase IV)
Before notifications consider if needed
Develop PR plan for potential media inquiries
Consider notification to Company senior management or others who should be notified before public
Prepare for inquiries from affected individuals - call center or other
If criminal and depending on seriousness and other factors, notify relevant law enforcement — local, FBI, Secret Service, or other
If required by law or recommended because individuals could do something to prevent further harm to themselves, make notifications to affected individuals. If made,
Include what happened, what the Company has done, and what the individual can do to prevent any harm
Include legally required information and resources available from government agencies
Consider an offer of identity theft prevention/ credit monitoring depending on nature of information compromised
Notifications to government agencies and Attorneys General as required by law
Other notifications as required by information at issue
Evaluate feedback from notifications and determine if additional steps/notifications are required
Phase VI: Post-Notifications Considerations
Disclosures to customers, stockholders, regulators etc.
Cost recoveries - responsible third parties, insurance, other
Consider longer-term security upgrades or other measures to prevent reoccurrence or similar events
Analyze data breach notification plan/checklist for necessary changes in light of lessons learned
Prepare final reports
Executive report with a summary of what happened, how it was addressed, what notifications were provided, and steps taken to prevent future incidents of the same or similar nature
Technical report with detailed background of the event; evidentiary backup for analysis, decisions, and conclusions; and evidence of preventative measures
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$TSNP #HUMBL Sanctions Program
This Sanctions Policy provides employees with the information and tools needed to comply with global sanctions regulations, and the procedures for employees to follow to assure such compliance. Any questions concerning sanctions compliance, or the information and attachments included in this manual should be addressed to the Company's Chief Compliance Officer.
I. Introduction
OFAC administers and enforces US economic and trade sanctions programs, which are designed to implement and support US foreign policy and national security goals. These sanctions programs are divided into two broad categories: comprehensive sanctions and targeted sanctions:
1. Comprehensive sanctions affect almost every aspect of trade with a given country;
2. Targeted sanctions are those aimed at one or more types of behavior or specific individuals within a country.
US sanctions are implemented through laws, regulations and executive orders. As part of its duty to implement and enforce US sanctions programs, OFAC maintains a list of over 5,000 individuals, sectors, and entities with whom US persons and entities may not do business absent specific authorization from OFAC.
Although each of the more than 20 sanctions programs administered by OFAC is unique, they all generally involve cutting off access to the US marketplace by prohibiting transactions in certain property (or interests in property) within the US or involving US persons, and/or requiring US persons to block (i.e., freeze) the property of those listed on OFAC’s list of Specially Designated Nationals and Blocked Persons (the ‘‘SDN List’’). Though not specifically listed in the OFAC SDN List, designations extend to entities that are 50% or more owned, directly or indirectly, by persons on the SDN List (whether alone or in conjunction with other listed persons). Therefore, not only is it illegal to do business with a person or company on the SDN List, it is also illegal to do business with any company that is 50% or more owned by a person on that list.
In addition to reviewing all customers and third parties against US sanctions lists, the company will also monitor for all sanctions and embargoes imposed by the United Nations, EU, UK, and any other relevant jurisdictions.
The Company and its employees are prohibited from engaging in any business or transaction with any person or entity on any of the above-mentioned sanctions lists, and any entity 50% or more owned by a person or entity on the OFAC SDN List. If a person or entity with whom the Company conducts business is added to any of the above lists after the Company began business with them, all such business will promptly cease, and the AML Compliance Officer will be contacted so instructions can be provided regarding the proper handling of blocked assets and funds. No actions may be taken without the approval of the AML Compliance Officer, including but not limited to: payments, purchases, sales, or even any action designed to terminate the relationship. Under OFAC's regulations, when a person or entity is added to the SDN List, all transactions are potentially subject to OFAC approval, and all assets are potentially blocked. Thus, even actions intended to extricate the Company from the relationship may require OFAC approval.
Sanctions may change fairly frequently in response to world events and global policies. As a result, sanctions regulations change often. Employees are expected to make every reasonable effort to comply with these regulations, including by ensuring that the people and entities with whom we conduct business with are not on any sanctions lists and, where clarification is needed, obtaining the necessary information from the Chief Compliance Officer.
Penalties for violations of sanctions laws apply to both the company and the individuals involved; these penalties can be severe and can involve both civil and criminal liability. Employees may not knowingly, willfully, or recklessly violate sanctions laws. Employees must immediately notify the AML Compliance Officer of any known or suspected violation of sanctions laws or regulations or contact by an individual or entity subject to these sanctions.
All employees are required to take all reasonable and appropriate steps to refrain from interacting with individuals in sanctioned countries and sanctioned parties in accordance with relevant laws. Sanctions policies, procedures, and internal controls are designed to achieve compliance with applicable sanctions requirements. While these policies and procedures will be updated to account for changes in sanctions, each employee must take responsibility for maintaining awareness of current sanctions requirements. Employees may contact the AML Compliance Officer with questions.
II. Sanctions Programs
OFAC administers a number of different sanctions programs targeting countries, geographic locations and types of activities. These sanctions programs block assets and apply trade restrictions to accomplish US foreign policy and national security goals. A complete list of OFAC’s sanctions programs may be found at https://www.treasury.gov.
Employees should consult the OFAC website or the AML Compliance Officer if there is any question about whether a country, person or entity may be subject to US sanctions.
Lists of Designated Persons and Entities
OFAC, the UN Security Council, the EU, and the Office of Financial Sanctions Implementation maintains list of individuals and entities with whom interactions by certain persons are limited or prohibited. These lists are frequently updated, and as a result, employees are expected to verify (known as "screening") whether a person or entity is on these lists prior to engaging in business with them. The Company uses a third party to help with screening.
Employees responsible for screening customers, vendors and others with whom the Company transacts business must be competent to conduct screening using sanctions tools, so sanctions training includes instruction on how to use these databases. If you are not certain whether a person or company has been screened, you should conduct the screening, or consult the Chief Compliance Officer.
The SDN List includes individuals, groups, and entities subject to the various sanctions programs and identifies the basis for the person’s or entity’s listing. US persons are generally prohibited from transacting business with a person or entity on the SDN List without specific OFAC authorization. In addition, the assets of people and entities on the SDN List are "blocked" and therefore we must submit to OFAC certain reports regarding the status of any blocked assets in its possession and portfolio.
III. Transactions Subject to OFAC Sanctions
OFAC regulations prohibit or restrict US persons and entities from undertaking or participating in transactions with sanctioned parties and in some cases even from interacting with sanctioned parties. Prohibited transactions include, but are not limited to financial transactions, investments and many other types of other business dealings. US persons may not engage in any prohibited transactions with sanctioned countries, entities, or people unless authorized by OFAC or expressly exempted by the sanctions regulations. Each sanctions program is based on different foreign policy and national security goals and prohibitions vary between programs, so employees are expected to act cautiously if contemplating transactions with sanctioned entities or persons, or those from countries subject to these sanctions.
Determining whether a potential transaction or undertaking could be subject to US sanctions requires employees to be familiar with some of the basic concepts applicable to US sanctions programs. This section outlines the basic factors to help identify when further inquiry is necessary and if necessary, when to consult with the Chief Compliance Officer.
OFAC sanctions apply to "US Persons," which includes:
US citizens and permanent residents;
Anyone physically present in the United States;
Companies legally organized under US law;
Foreign branches of US companies (i.e., entities abroad that are not separately incorporated); and
Foreign entities owned or controlled by US companies.
IV. Direct and Indirect Transactions
To ensure that the Company does not do business directly with a prohibited individual or company, employees should be vigilant for red flags that suggest potential sanctions issues and should consult with the AML Compliance Officer whenever there is doubt or concern.
Doing business with a sanctioned target indirectly, or where the involvement of the sanctioned party is not readily apparent, is more difficult to identify and protect against. While screening individual, entity, or country names and other identifying information can help alert firms to possible red flags in transactions, identifying the indirect involvement of a sanctioned party requires extra scrutiny and due diligence. All reasonable efforts must be taken to resolve any open questions or issues to reduce the risk that the Company will end up doing business that violates US sanctions.
V. Identifying Risks
Risks can arise in almost any type of transaction, including investments involving a sanctioned person or entity and investments located in a country subject to comprehensive sanctions. Because sanctions issues may also arise through any relationship, even if the party with whom The Company is interacting directly is not subject to sanctions, the Company must perform sufficient due diligence to identify and screen all partners in a partnership, regardless of the level of interaction the Company has with them.
VI. Facilitation
Facilitation is defined broadly under sanctions regulations and can include almost any action that assists a transaction that violates sanctions. Thus, facilitation includes activities by a person such as approving, guaranteeing or supporting a transaction if the transaction would otherwise be prohibited. To avoid being charged with facilitation, employees may not assist or support any person or entity with any transaction that the Company cannot itself perform under sanctions laws. Thus, employees should avoid any questionable actions, including but not limited to:
Referring prohibited business opportunities;
Changing operating practices and procedures to avoid the detection of a violation of sanctions;
Giving approvals for prohibited transactions; and
Providing support for prohibited transactions.
VII. No Grandfathering
Sanctions are typically effective immediately upon issuance of an Executive Order, and impact current relationships and dealings in addition to future dealings. Generally speaking, a "hands-off" approach is required from the moment sanctions go into effect until the governing body grants a license or until the sanctions are lifted. Even if the Company wishes to dispose of its interest in an investment that has become subject to sanctions or remove a partner who has been placed on sanctions list, regulatory approval is required. If a party or country relating to a current investment or partnership becomes subject to sanctions, no further action may be taken until approved by the Chief Compliance Officer.
VIII. Compliance Procedures
Having an adequate sanctions compliance program in place is important, both to prevent violations and to reduce penalties in the event that violations do occur. When deciding whether to take an enforcement action, regulatory bodies consider not only the illegal actions, but also, the adequacy of a company's sanctions compliance program. The Company is committed to having a strong compliance program, primarily to assure that no violations occur, but secondarily to demonstrate the Company’s commitment to compliance in the event inadvertent violations happen. As part of this effort, employees shall complete annual training. In addition, the internal controls and procedures outlined below shall be followed by all employees at all times.
IX. Identifying Sanctions Compliance Risk
The Company will use a risk-based approach to compliance that balances the likelihood of sanctions involvement in a transaction against the costs associated with identifying all indirect involvements. Employees are expected to use diligence in assessing the risk of sanctions non-compliance and consult with the AML Compliance Officer when questions arise.
Screening must be performed for transactions and parties involved prior to engaging in the transaction. Before engaging in any transaction, the Company will verify that the parties to the transaction (i) do not appear on any sanctions lists; and (ii) are not located in, and do not involve individuals or entities in jurisdictions subject to US, EU, or UK sanctions. The names of parties involved in a transaction will be individually checked against the above-mentioned lists.
The AML Compliance Officer shall periodically review the third party tool that maintains the sanctions lists properly and test to ensure updates to the lists and to sanctions programs are incorporated.
In the event that the Company identifies potential involvement in a transaction with a party on the lists or a person from a jurisdiction subject to sanctions, the Company will, as appropriate, decline to engage in the transaction or request a license.
X. Licenses
A license is an authorization from OFAC to engage in a transaction that otherwise would be prohibited. Licenses are issued in limited circumstances and can be general or specific.
XI. General Licenses
Most OFAC regulations include General Licenses, which exempt certain transactions from the restrictions placed by the sanctions regulations. A general license is a pre-approved authorization to conduct activity if all elements of a general license are satisfied. These general licenses authorize the performance of certain categories of transactions, or the provision of certain types of trade or services. No additional written approval is required from OFAC.
Before processing transactions that may be covered under a general license, employees must verify that the transaction meets the relevant criteria of the general license. If there are any questions regarding the applicability of a general license, consult with the Chief Compliance Officer.
XII. Specific Licenses
When a party wants to engage in a transaction, and no general license exists, a written request for a specific license may be filed with OFAC. OFAC issues specific licenses on a case-by-case basis, if the transaction conforms to OFAC's internal licensing policies and US foreign policy objectives. Specific licenses must be obtained prior to conducting the activity. Specific licenses authorize only the particular transaction or set of transactions and are limited to a specified time period, generally, one (1) year. License approvals contain specific limitations and conditions that must be followed.
Only the AML Compliance Officer may apply for a specific license from OFAC on behalf of the Company. The Company will not take action with regard to a transaction or property requiring a license until such license is received or until the sanctions are lifted.
XIII. Reports and Records
OFAC requires reporting of certain transactions and the existence of certain blocked property. Employees shall inform the AML Compliance Officer if they believe that the Company possesses blocked property subject to OFAC reporting requirements. The AML Compliance Officer will submit all required OFAC reports after consultation with the General Counsel.
Sanctions compliance records shall be retained for at least five (5) years from the later of the date of the event or the expiration of the authorization for the event, and shall include at least the following records:
Records of reports and blocked and rejected transactions;
Copies of all licenses, including submissions; and
Records of screening.
XIV. Training
Training is a critical element to ensure that employees understand the requirements for compliance with sanctions regulations. Employees shall receive (or complete) general sanctions training annually.
XV. Responsible Individual
The AML Compliance Officer has been designated as the individual responsible for day-to-day compliance with sanctions, including reporting to the relevant regulatory bodies and requesting licenses from OFAC, and will maintain an appropriate level of knowledge about sanctions regulations commensurate with Company’s sanctions risk profile.
XVI. Sanctions Violations
An individual or entity that violates sanctions regulations is potentially liable for that violation and subject to civil penalties, regardless whether the violation occurred with intent. Further, someone who intentionally or willfully violates sanctions regulations can be subject to criminal fines or imprisonment. Therefore, diligence is good not only for the Company but for all employees, personally and financially. OFAC, OFSI, the UN and the EU may mitigate penalties depending upon the nature of the violation and the party’s cooperation.
Important factors in this decision making include the compliance program in place and whether the violation was voluntarily disclosed. To that end, the AML Compliance Officer will determine whether violations or potential violations will be voluntarily disclosed and will further be responsible for those disclosures, working with outside counsel, where appropriate.
If you have any questions regarding sanctions compliance, or you believe a violation of global sanctions laws or regulations has occurred, please inform the AML Compliance Officer immediately.
LAST UPDATED: April 6, 2020
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$TSNP #HUMBL Anti-Bribery and Corruption Policy
1. ANTI-BRIBERY POLICY STATEMENT
Bribery is both a criminal offense and bad business. Not only can individuals be guilty of an offense but a company can be prosecuted if it fails to prevent bribery, whether in the US, UK or any other jurisdiction. Without exception, HUMBL LLC acts with integrity in all of its dealings and strictly prohibits bribery and corruption in any form. HUMBL LLC commits itself to:
(a) conducting its business fairly, honestly, accountably and transparently;
(b) not making, offering or accepting inducements or bribes, whether directly or indirectly, to gain business advantages or for any other purposes;
(c) not using a third party as a conduit, whether directly or indirectly, to channel bribes or other inducements to others; and
(d) developing a program to implement and support these principles. These are the values by which HUMBL LLC expects its staff to carry out its work on its behalf.
As a unique, private organization, which is required to be both publicly accountable and transparent in all of its work, HUMBL LLC is committed to following the principles of integrity, transparency and accountability. A key part of corporate integrity is complying with all applicable rules, including but not limited to the US’s Foreign Corrupt Practices Act and the UK’s Bribery Act 2010.
a. BRIBERY DEFINED
Bribery is a reward or an inducement, financial or otherwise, offered, promised or provided to improperly gain personal, commercial, regulatory or contractual advantage. It is unacceptable to:
(a) give, promise to give, or offer a payment, gift, hospitality or other financial advantage with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
(b) give, promise to give or offer a payment, gift, hospitality or other financial advantage to a government official, agent or representative to ‘facilitate’ or expedite a routine procedure;
(c) accept or solicit payment, gift, hospitality or any other financial advantage from a third party that they know or suspect is offered with the expectation that it will obtain a business advantage for them;
(d) accept a payment, gift, hospitality or any other financial advantage from a third party if they know or suspect that it is offered or provided with an expectation that a business advantage will be provided by HUMBL LLC in return;
(e) retaliate against or threaten a person who has refused to commit a bribery offense or who has raised concerns under this policy;
(f) do something that is improper, illegal or a breach of trust in the course of working or doing business; and/or
(g) engage in any other activity that is in breach of this policy.
b. WHO DOES THIS POLICY APPLY TO?
All HUMBL LLC employees are required to abide by these rules. In addition, anyone who carries out work on behalf of HUMBL LLC must abide by these rules, including:
(a) Trustees;
(b) Directors and other employees;
(c) consultants;
(d) secondees; and
(e) agency staff and casual workers or locum staff brought in to cover absent staff.
c. WHAT CAN HAPPEN IF THE POLICY IS VIOLATED?
HUMBL LLC staff can be responsible for acts of corruption and bribery committed on its behalf, anywhere in the world, even without HUMBL LLC’s knowledge. HUMBL LLC expects all those who are obliged to follow those rules to abide by the following principles:
(a) ensure that they read, understand and comply with this policy;
(b) sign the declaration that confirms the above; and
(c) raise concerns as soon as possible if they believe or suspect that a conflict with this policy has occurred, or may occur, in the future. Any violation of this policy by an individual acting on HUMBL LLC’s behalf may result in disciplinary action up to and including summary dismissal for gross misconduct and/or termination of the business relationship. In addition, staff and trustees should note that the penalties for violating the relevant legislation against bribery and corruption are both civil and criminal and include fines and imprisonment for individuals. The penalties for HUMBL LLC may include unlimited fines and significant reputational damage.
2. RESPONSIBILITY FOR IMPLEMENTATION AND MONITORING
Within HUMBL LLC, the responsibility to control the risk of bribery and any other corruption occurring resides at all levels of personnel. It does not rest solely with one director or manager, or within a single department. If any individual has concerns or questions arising from this policy, it can be addressed to any of the directors in HUMBL LLC.
a. HUMBL LLC’s ANTI-BRIBERY PRINCIPLES
HUMBL LLC expects all those who are obliged to follow these rules to abide by the principles set out below:
(a) to carry out our business with integrity, honestly, accountably and transparently;
(b) to not pay or offer to pay bribes or inducements of any nature, nor to condone the offering of bribes or inducements on our behalf to any third party and, in particular, to public officials, to gain or seek to gain new business or a business advantage.;
(c) to not accept bribes or inducements, and nor will we agree to them being accepted on our behalf in order to influence our work;
(d) if a member of staff becomes aware that any appointed adviser, or business associate, has violated this policy, they should immediately inform the Chief Compliance Officer, and HUMBL LLC will immediately terminate its relationship with that individual or organization. It will not be associated with any person or organization that may harm our reputation;
(e) to set out HUMBL LLC’s processes for avoiding direct or indirect corruption and bribery and abiding by and supporting its values;
(f) the staff will safeguard the organization and its resources for which they are responsible, and will keep clear records of any gifts, corporate hospitality and donations received and given to a value greater than $100;
(g) to make sure that everyone working for HUMBL LLC knows and understands its policies and the principles that it has established; and
(h) to regularly review and update these rules and the procedures that are relevant to their implementation.
b. COMPLIANCE IS MANDATORY
HUMBL LLC will always ensure that no employee will suffer dismissal, demotion or any other penalty or adverse consequence for refusing to engage in, or for reporting, questionable conduct. This is true, even if HUMBL LLC may suffer as a consequence. HUMBL LLC insists on the strict compliance with this policy by all staff and others to whom this policy applies.
c. FACILITATION PAYMENTS
Many countries do not make a distinction between facilitation payments and bribery. Facilitation payments are small payments made directly or indirectly to secure or speed up the performance of a routine action or to avoid bureaucratic delays, for example, the issuing of permits by public officials or for goods to clear customs. HUMBL LLC will not tolerate facilitation payments, because they are illegal.
3. Gifts and Hospitality Policy
Because bribes and inducements can sometimes be disguised as gifts, or gifts can sometimes be misinterpreted as bribes, HUMBL LLC must ensure that giving or receiving gifts cannot distort its business relationships, create a conflict of interest, or be otherwise construed as an inducement. A conflict of interest may also arise by the giving or receiving of favors or special treatment to which no financial value can be attached. Such special treatments generally encourage a ‘payback’ expectation and can distort a professional relationship. This policy makes it clear that:
(a) Staff should not accept gifts or any other consideration of a value greater than £100 from any person having business with HUMBL LLC without having first obtained the permission of the Executive Director or Director of Operations, who may wish to record such information in an appropriate manner. Discretion should always be exercised in accepting hospitality. Excessively generous hospitality, however innocently offered, is always liable to misinterpretation.
(b) Sample tokens of modest value bearing the name or insignia of the organization giving them (for example, pens, diaries or calendars), whether given personally, or received in the post, may be retained unless they could be regarded as an inducement or reward.
(c) If staff are invited to attend a meeting, present a speech or submit a written article, all speaking fees, article fees and honoraria should be paid over to HUMBL LLC.
(d) If staff are invited to speak or attend a commercial conference that has been organized for profit, they must seek their line manager’s prior agreement.
a. GIFT REPORTING
Details of any gifts, corporate hospitality and donations received, in excess of value of $100, other than branded goods, must be notified to the Director of Operations on a monthly basis.
b. CHARITABLE CONTRIBUTIONS AND BEQUESTS
HUMBL LLC and its staff must be vigilant to ensure that any charitable contribution or bequest is not used as a means of concealing or disguising bribery. As a not-for-profit organization, HUMBL LLC does not regularly make charitable donations to organizations. However, should HUMBL LLC deem it necessary to make a payment to a charitable organization or educational fund, only the Trustees are permitted to make such a decision. A donation or payment must never be made in order to gain favor or influence.
c. RAISING A CONCERN
HUMBL LLC is committed to ensuring that all individuals have a safe, reliable and confidential way of reporting any suspicious activity. If staff have a concern about a suspected instance of bribery or corruption, they should speak up—their information and assistance will help. The sooner they act, the sooner it can be resolved. There are various channels to help staff to raise concerns. Staff should disclose and resolve their concerns internally, wherever possible, by reporting the matter to their line manager and/or a director or otherwise the Chief Compliance Officer, Chief Operating Officer, or any other member of the senior management team. Where internal disclosures may be inappropriate, concerns can be raised with:
(a) An external auditor;
(b) relevant professional bodies or regulatory organizations; or
(c) the police.
Raising concerns in these ways may be more likely to be considered reasonable than making disclosures publicly (for example, to the media). Concerns can be raised anonymously. In the event that an incident of bribery, corruption or wrongdoing is reported, HUMBL LLC will act as soon as possible to evaluate the situation. Staff who refuse to accept or offer a bribe, or those who raise concerns or report wrongdoing, may be worried about the repercussions. HUMBL LLC is committed to ensuring nobody suffers detrimental treatment through refusing to take part in bribery or corruption or because of reporting a concern in good faith. If staff have any questions about these procedures, they should contact the CCO or COO.
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$TSNP #HUMBL Safe Harbor Statement
This website contains forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. You can identify these statements by the use of the words "may," "will," "should," "plans," "expects," "anticipates," "continue," "estimates," "projects," "intends," and similar expressions. Forward-looking statements involve risks and uncertainties that could cause results to differ materially from those projected or anticipated. These risks and uncertainties include, but are not limited to, the Company's ability to successfully execute its expanded business strategy, including by entering into definitive agreements with suppliers, commercial partners and customers; general economic and business conditions, effects of continued geopolitical unrest and regional conflicts, competition, changes in technology and methods of marketing, delays in completing various engineering and manufacturing programs, changes in customer order patterns, changes in product mix, continued success in technical.
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$TSNP #HUMBL Anti-Fraud and Consumer Protection
HUMBL LLC (“HUMBL” or the “Company”) takes its customers’ financial safety and security seriously. The Company understands that in this digital age, there are fraudsters that attempt to steal both customer’s money and identity. Fraud can come in many different forms, so we monitor for unusual and suspicious activities in our customers’ accounts through transaction monitoring and daily operations reports. The Company’s compliance, cybersecurity, and data engineering teams play active roles in striving to detect possible fraudulent activity.
When such activity is discovered, HUMBL acts to neutralize it as quickly as possible and inform the parties involved so they can take steps to protect themselves from the attempted fraud.
The HUMBL family of affiliated companies exists in a regulated environment that is governed by both federal and state laws relating to financial institutions. Accordingly, it is necessary for all HUMBL entities to maintain fraud prevention procedures.
Two of the important forms of fraud that HUMBL seeks to detect are 1) identity fraud and 2) account takeovers.
Please refer to the AML Program for detailed information on the Identity Theft Prevention Program, which outlines HUMBL’s procedures for preventing these types of fraud.
Please refer to the Cybersecurity Policy for detailed information on account information protections, which outlines HUMBL’s approach for preventing these types of fraud.
To strengthen employees’ support of such anti-fraud efforts, HUMBL maintains a Code of Conduct and Ethics and provides training to employees relating to the Code and the Company’s anti-fraud efforts including, without limitation, AML and cybersecurity/privacy.
Additionally, the Company provides required disclosures to customers before they consummate transactions, designed to describe product features including material risks associated with establishing an account and transacting with e-wallets. For example, the Terms of Use, Frequently Asked Questions and/or website disclosures will cover the following:
(1) Legislative and regulatory changes or actions at the state, federal, or international level may adversely affect the use, transfer, and exchange of legal tender in a virtual manner;
(2) Transactions may be irreversible, and, accordingly, losses due to fraudulent or accidental transactions may not be recoverable;
(3) There is no assurance that a person who accepts a payment today will continue to do so in the future;
(4) The nature of e-wallets and online commerce may lead to an increased risk of fraud or cyber attack; and
(5) Any bond or trust account maintained by HUMBL for the benefit of its customers may not be sufficient to cover all losses incurred by customers.
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Copyright 2020 HUMBL
®
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$TSNP #HUMBL Privacy Policy
Effective Date: June 01, 2020
Welcome to HUMBL® LLC (“HUMBL”, “we,” “us” or “our”). We know you take your privacy seriously, and we respect your privacy and are committed to protecting it through compliance with this privacy policy (“Privacy Policy”). Please take the time to read, review and familiarize yourself with this Privacy Policy, which describes the types of information HUMBL, as a data controller, may collect from you or that you may provide and our practices for collecting, using, maintaining, protecting and disclosing that information.
HUMBL’s Terms of Use [hyperlink] (the “Terms”), along with this Privacy Policy, govern your access to and use of the Services and applies to all of the websites and mobile applications that we own and operate.
Capitalized terms not otherwise defined in this Privacy Policy have the same meaning as used in the Terms. For the avoidance of doubt, the use of the term “HUMBL” in this Privacy Policy includes HUMBL.
Acceptance of Privacy Policy
You acknowledge and agree that by visiting, using or accessing the Services in any manner, you accept the practices and policies outlined in this Privacy Policy, and you consent to the procedures we employ to collect, use, and share your information as outlined in this Privacy Policy. If you do not consent to any of the terms or procedures described in this Privacy Policy, you should NOT access or use any of the Services.
You further acknowledge and agree that by visiting, using or accessing the Services in any matter, you accept the practices and policies outlined in the Privacy Policy [hyperlink] of NIUM, our backend software provider and provider of certain banking services for HUMBL.
Updates & Changes to Privacy Policy
HUMBL reserves the right to, in its sole discretion, change, amend or modify the Privacy Policy at any time to reflect changes in our data and information practices. If we modify or update this Privacy Policy, we will post changes and updates on this Site so that you will always be aware of what information we collect, use and disclose. Even if you do not receive a notification regarding any updates to the Privacy Policy, the amended terms of the Privacy Policy will govern your use of the Services. You are responsible for reviewing and understanding the Privacy Policy and any modifications to it. Accessing or using the Services in any way following a change to the Privacy Policy indicates your acceptance and consent to the amended policy. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected. The date of the last update of the Privacy Policy is indicated at the top of this Privacy Policy.
What Does This Privacy Policy Cover?
“Personal Information” is all data or information that HUMBL gathers when you register for a HUMBL Account or when you access or use the Services, which can be used to (i) identify you, either directly or indirectly, or (ii) contact you. This Privacy Policy covers our treatment of all Personal Information, including that which you voluntarily submit to us and/or are required to submit pursuant to applicable law, that which is automatically generated and that which we obtain from our partners or other third parties.
This Privacy Policy does not cover the practices of companies we do not own or control, or people that we do not manage.
What Information Does HUMBL Collect?
Information You Provide to Us:
We receive and store any Personal Information you knowingly provide to us—either voluntarily or as required by law.
For example, we may collect the following Personal Information when you register for a HUMBL Account and as you access or use our Services:
full legal name,
address,
email address,
mobile phone number,
proof of identity (e.g., driver’s license, passport, or government-issued identity card),
Social Security Number, Tax Identification Number, or other comparable government-issued identification number,
date of birth,
home address,
bank account details and/or credit card numbers, and
other personal, commercial and/or taxpayer or government identification information (e.g., any information we, in our sole discretion, deem necessary to comply with our legal obligations under various anti-money laundering (“AML”) laws).
Information Collected Automatically
We receive and record certain types of information automatically, such as whenever you interact with or access the Services. For example, we automatically receive and record information from your browser, including your IP address, your geographic location, device type and unique device identification numbers, and technical data collected through cookies (as discussed below), pixel tags and other similar technologies that identify your browser.
“Cookies” are small data files placed on your browser, computer or other devices when you visit certain websites, which are intended to recognize your device when you return to our website or related websites. We use cookies to help us recognize you as a user, collect information about your use of HUMBL, and collect information about your computer or other devices. Cookies enable us to better customize our Services and Content for you.
Cookies we place on your browser or device are called “first party cookies.” Cookies set by our partners or other third parties are called “third party cookies.” Cookies set by third parties can recognize your device when you visit the HUMBL website, as well as certain other websites or mobile applications.
Cookies can either be “session cookies” or “persistent cookies.” Session cookies are temporary: they stay on your device only while you are visiting our website or accessing our Services. “Persistent cookies” stay on your browsing device until they expire or are deleted.
We—and our affiliates and/or service providers—use the following types of cookies:
Essential Cookies: Essential cookies allow you to navigate and use certain features of our Services. For example, certain essential cookies enable you to access secure areas of our Services. Without these cookies, some Services may be unavailable to you.
Functional Cookies: Functional cookies allow us to record your choices and settings regarding our Services. These cookies help us personalize our content for you, greet you by name, and remember your preferences.
Performance/Analytics Cookies: Performance/analytical cookies allow us to understand how you use our Services and website. For example, these cookies register information about the number of visitors to the website, the most frequently-viewed pages on our website and the length of time users view particular pages on our site.
Advertisement Cookies: Advertising cookies allow us and third parties serve relevant ads to you more effectively and help us collect aggregated audit data, research, and performance reporting for advertisers. They also enable us to understand and improve the delivery of ads to you and know when certain ads have been shown to you. Your web browser may request advertisements directly from ad network servers, these networks can view, edit, or set their own cookies, just as if you had requested a web page from their website. Although we do not use cookies to create a profile of your browsing behavior on third-party sites, we do use aggregate data from third parties to show you relevant, interest-based advertising. We do not provide any personal information that we collect to advertisers.
Social Media Cookies: Third-party cookies from social media sites (such as Facebook, Twitter, etc) let us track social network users when they visit our Website, use our Services or share content, by using a tagging mechanism provided by those social networks. These cookies are also used for event tracking and remarketing purposes. Any data collected with these tags will be used in accordance with our and social networks’ privacy policies. We will not collect or share any personally identifiable information from the user.
If you choose to prevent or limit your device’s acceptance of cookies on your browser or device, you may not be able to use or access all of our Services. If you do not consent to the placing of cookies on your device, do not access or use our Services.
We may also collect information from publicly available sources. We do not link information obtained from Cookies to other personal information.
Our emails may contain a "web beacon" (or "tracking pixel") to tell us whether our emails are opened and verify any clicks through to links or advertisements within the email. We may use this information for purposes including determining which of our emails are more interesting to users and to query whether users who do not open our emails wish to continue receiving them. The pixel will be deleted when you delete the email. If you do not wish the pixel to be downloaded to your device, you should read the email in plain text view or with images disabled.
Information Collected from Other Sources
We work closely with third parties who may provide certain Personal Information to us, such as:
basic personal information (e.g., name and address) from the banks you use to transfer money, public databases, credit bureaus or our business partners;
other personal, commercial and/or identification information (e.g., information we, in our sole discretion, deem necessary to comply with our legal obligations under various AML laws) from business partners who may use a combination of government records and other publicly available information to verify your identity; and
your financial information (e.g., your bank account details) from the banks you use to transfer money to us.
Credit reference agencies do not provide us with any personal information about you but may be used to corroborate the information you have provided to us.
How Does HUMBL Use My Personal Information?
HUMBL primarily uses Personal Information to customize, develop, operate, and improve our Services, including by implementing preferences requested by our users.
We also use Personal Information gathered from our users to:
Verify your identity and allow you to activate a HUMBL Account;
Protect us and our proprietary materials, including the Content;
Enhance security for our users, including by monitoring and verifying user identity as well as combatting malware, viruses or other security risks;
Comply with applicable laws requiring us to collect certain Personal Information, including AML laws;
Contact you and allow other users to contact you;
Analyze your use of the Services, including to personalize content based on your usage patterns; and
and for other legitimate business purposes.
In certain cases, we may share some Personal Information with third parties, but only as described below. We will disclose any information we collect, use or receive if required or permitted by law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account, and personal data will likely be among the assets transferred.
Why Is HUMBL Permitted to Process My Personal Data?
We rely on the following bases to process your Personal Information:
Consent: We may use your Personal Information as described in this Privacy Policy subject to your consent. To withdraw your consent, please contact us at support@humbl.io. Please also see the section below regarding your rights and choices.
Performance of a contract: We may need to collect and use your Personal Information to enter into an agreement with you or to perform an agreement that you have with us. When we process Personal Information on behalf of third parties, we do so in performance of agreements with such third parties.
Legitimate Interests: We may use your Personal Information for our legitimate interests to provide our Services and to improve our Services and the Content. We process information on behalf of third parties who have legitimate interests in operating their businesses. We may use technical information as described in this Privacy Policy and use Personal Information for our marketing purposes consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable law.
When and With Whom Does HUMBL Share My Personal Information?
HUMBL may share your Personal Information with third parties who have a legitimate purpose for accessing it. We will never sell, rent or otherwise profit from your Personal Information.
We will share your Personal Information in the following circumstances:
Service Providers: We employ other companies and people to assist with parts of our business operations and perform tasks on our behalf. Where necessary, we will share your Personal Information with these service providers in order to deliver the Services to you. For example, we may provide your Personal Information to identity verification services to perform KYC and AML checks and to prevent fraud; to the custodian who provides services for and access to the e- Wallet; to bill collection, marketing, and technology services; or to financial institutions or payment processing companies to receive and process your payment information or credit card transactions.
Specifically, we provide certain Personal Information to NIUM in order to allow you to open a HUMBL Account. However, our contract with NIUM requires that it only uses your Personal Information in connection with the services they perform and for compliance with applicable law and regulation, and prohibits it from disclosing, using or selling your Personal Information except with its partner financial institution.
Unless we tell you differently, our service providers do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.
Change of Control/Transfer of Assets: If we engage in any potential business transaction, including selling our assets, we may disclose your Personal Information in an anonymized form in connection with the evaluation of such transactions. In the event of a merger, acquisition, or other corporate combination, or if we go out of business or enter bankruptcy, we may transfer or sell Personal Information to a third party. We will provide notice to you prior to any transfer of your data to another company or person through a change of control or other corporate combination.
As Required by Law: We reserve the right to access, read, preserve, and disclose any Personal Information to comply with law or court order, including to verify your identity, prevent and detect fraud and crime, conduct or cooperate in investigations of fraud or other illegal activity, enforce or apply our Terms [hyperlink], or protect the rights, property, or safety of HUMBL, our employees, our users, or others.
In Anonymized Form: HUMBL may use your Personal Information to create aggregated and anonymized data about our Services or the user thereof and provide such information to our partners. In anonymizing your Personal Information or aggregating usage information, we will ensure you are not identifiable as an individual.
Affiliates: We may disclose information about you to our affiliates for the purpose of being able to offer you related or additional products and services. Any information relating to you that we provide to our affiliates will be treated by those affiliates in accordance with the terms of this Privacy Policy.
Advertisers: We may display online advertisements and we may share aggregated and non-identifying information about our customers that we collect through the registration process or through online surveys and promotions with certain advertisers. We do not share personally identifiable information about individual customers with advertisers. In some instances, we may use this aggregated and non-identifying information to deliver tailored advertisements to the intended audience.
How Does HUMBL Protect My Personal Information?
HUMBL takes the security of your Personal Information seriously and has implemented reasonable and commercially viable administrative, physical and technical security measures to help ensure that Personal Information is not lost, abused, altered or open to unauthorized use and/or disclosure. We cannot guarantee that all transmission of data over the Internet or through a blockchain network is completely secure or error-free.
We cannot guarantee complete security of the Personal Information we hold in our records. For that reason, you acknowledge and agree that you are responsible for safeguarding, protecting—and preventing unauthorized access to—your Personal Information and your HUMBL Account. You agree to protect the password for, and any other security information related to, your HUMBL Account, to limit access to the computer(s) or device(s) you use to access the Services, and to sign out of your HUMBL Account after you have completed accessing the Services. We will not be liable for privacy violations that arise from your errors or negligent use of the Services or for processes and networks that we do not control and for unauthorized access to information by those who have gained access through unlawful means.
If you suspect that your Personal Information or your HUMBL Account has been compromised, immediately contact HUMBL Customer Support at support@humbl.io.
What Are My Rights & Choices Relating to My Personal Information?
It is your right not to disclose Personal Information to us. However, where you fail to provide Personal Information required by law or otherwise required to open a HUMBL Account, we may not be able to register you to use or access the Services or may terminate your HUMBL Account.
You have the right, through your HUMBL Account, to access and view certain Personal Information you provided to us, including your name and password, your email address, your transaction history and information relating to your use of the Services.
In addition, you have the right to determine whether we hold accurate and current Personal Information about you, to request a copy of the Personal Information we hold about you pursuant to applicable law, and to update your Personal Information. Note, however, that we may maintain a copy of the prior Personal Information in our records.
You have the right to request that we delete certain Personal Information about you or that we delete your HUMBL Account by contacting HUMBL Customer Support at support@humbl.io. Pursuant to applicable laws, including those relating to the BSA and AML, we may retain certain information about you even after you request that we delete your Personal Information or terminate your HUMBL Account.
In certain circumstances, you have the right to receive the Personal Information you have provided to us in an electronic format and to request that we transmit that Personal Information to another data controller.
Disclosures for California Users
California Information-Sharing Disclosure: California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed. If you are a California resident and want such a list, please send us a written request by email to support@humbl.io with “California Privacy Rights” in the subject line.
California Right to Object: If you are a California resident, to the extent provided under California law, you may object in writing to the sale or other sharing of your personal information, and we will refrain from doing so without an economic impact on you, except to the extent, if any, that our inability to make use of your data impacts the economic value of our business relationship.
California Do Not Track Disclosure: We do not currently recognize or respond to browser-initiated Do Not Track signals as there is no consistent industry standard for compliance. Depending on the browser you are using, you may be able to choose to block third party cookies or browse in a private browsing mode. The Services and the HUMBL website are accessible even when private browsing is turned on. The information we collect is governed by this Privacy Policy.
How Long Does HUMBL Keep My Personal Information?
We retain the Personal Information we collect for so long as reasonably necessary to fulfill the purposes for which the data was collected, to perform our contractual and legal obligations, and for any applicable statute of limitations periods.
Privacy of Minors
HUMBL does not knowingly collect or solicit Personal Information from anyone under the age of 18. If you are under 18, do NOT attempt to access or use the Services and do NOT send any Personal Information to us. If we learn that we have collected Personal Information from a person under age 18, we will delete and/or destroy that information as quickly as reasonably possible and close any HUMBL Account associated with it. If you know that a person under the age of 18 is using our Services or provided Personal Information to us, please contact HUMBL Customer Support at support@humbl.io.
Links to Other Sites
HUMBL may include links to third party sites on the HUMBL website or when you are accessing the Services. The inclusion of any link does not imply that we endorse the products and services offered at such linked site. These third-party sites have separate and independent privacy policies which we encourage you to review. We therefore have no responsibility or liability for the content and activities of these linked sites.
Contact HUMBL
If you have any questions or concerns regarding this Privacy Policy or otherwise would like to contact HUMBL, please send HUMBL Customer Support an email at support@humbl.io.
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Copyright 2020 HUMBL
®
LLC
$TSNP #HUMBL Terms and Conditions
Effective Date: June 1, 2020
Welcome to HUMBL® LLC (“HUMBL,”“we,” “us” or “our”). These Terms of Use (the “Terms”) are a binding contract between you and HUMBL, and govern your use of any and all HUMBL website(s), apps, products, and services ,as well as all tools, features, and services provided on or through our platform, such as HUMBL Financial Services, HUMBL Hubs, HUMBL Mobile Payments, and all others (collectively, the “Services”).
By accessing any HUMBL website, app, or any other product/service, by signing up for an account with HUMBL, or by clicking “Agree” when prompted, you agree that you have read, understood and accepted all of the Terms, as well as HUMBL’s privacy policy (the “Privacy Policy”) governing the Services. If any term or condition of the Terms is unacceptable to you, please do not visit, access, or use the Services.
In addition, and as set forth further below, if you choose to use certain Services on HUMBL, you not only agree to HUMBL’s Terms, but also to the Terms of Service for NIUM, LLC (“NIUM”), HUMBL’s backend software provider and provider of certain banking services for HUMBL. NIUM’s Terms and Conditions
NOTICE: Please read these Terms and the Privacy Policy carefully as they govern your use of the Services.
1. Agreement Conditions
HUMBL reserves the right to, in its sole discretion, change, amend or modify theTerms at any time. HUMBL will notify you of any changes in any number of ways: updating the Terms on the HUMBL site, sending you an email notifying you of the changes, updating the “Effective Date” at the top of the Terms and/or by another means. By clicking an “Agree” button presented with the amendedTerms or by continuing to access or use any of the Services after a revision to the Terms, you confirm your agreement to the amended Terms.
If you do not agree with any changes to the Terms at any time, you should NOT click “Agree” if prompted todo so or continue to access or use any of the Services. Accessing or using the Services in any way following a communicated change to the Terms indicates your acceptance of the amended Terms.
2. Eligibility
By agreeing to these Terms, you represent that you are at least the age of majority in your state or province of residence, are an individual, legal person or other organization with full legal capacity and authority to enter into these Terms, and have not previously been suspended or removed from using our Services.
HUMBL maintains the right to select the markets and jurisdictions in which theServices are available, and may, at its sole discretion, restrict or prohibit the Services in certain locations (“Restricted Locations”). For that reason, the range of Services available to you will depend upon the location from which you access the Services. You may not use the Services if you are located in, or a citizen or resident of, any Restricted Location, or where your use of the Services would be illegal or otherwise violate any applicable law.
3. Account Registration and Requirements
a. Registration
In order to access the Services, you must register for an account (a “HUMBLAccount”). When registering for a HUMBL Account, you must select a user name (a “HUMBL User ID”). You may not select as your HUMBL User ID a name that you do not have the right to use, or another person’s or entity’s name with the intent to impersonate that person/entity. You may not transfer your HUMBL Account to anyone else without our prior written permission.
b. Identity Verification
When registering for a HUMBL Account, you agree to provide current, accurate, and complete information for all required fields on the registration page. You are solely responsible for any improper or unlawful activity in connection with the registration of your HUMBL Account ,including any misrepresentations made in connection with the creation of your account.
You hereby authorize HUMBL, directly or through third parties and through use of your mobile carrier, to make any inquiries HUMBL deems necessary to verify your identity, protect against fraud or other financial crime, and/or comply with our legal obligations under various anti-money laundering (“AML”) obligations, such as under the U.S. Bank Secrecy Act (“BSA”). When we carry out these inquiries, you acknowledge and agree that your personal information may be disclosed to credit reference and fraud prevention or financial crime agencies and that these agencies may respond to our inquiries in full. You further authorize HUMBL to take whatever action we deem reasonably necessary based upon such inquiries. You acknowledge that your mobile carrier may share your mobile subscriber details with HUMBL for identity verification purposes.
c. Account Usage
You are the only person authorized to use or access your HUMBL Account. By registering for a HUMBL Account, you agree and represent that you will use the Services only for your own personal, non-commercial use, and not on behalf or for the benefit of any third party, unless you have obtained prior that complies with all applicable laws.
You are solely responsible for all activity that occurs under your HUMBL Account or with your HUMBL User ID, including any fraudulent activity.
The bank or other provider of anAccount (the "Account Provider") may impose additional fees on anAccount. The agreement with the Account Provider governs use of an Account and provides the rights and liabilities of the holder of an Account. Unless required by applicable law, HUMBL accepts no responsibility to You or anyAccount holder for any fees imposed by an Account provider. If the currency You select for a transaction is not the currency in which an Account is denominated, the Account provider may convert the funds at its own currency exchange rate or reject the transfer. Account Services are for personal or individual use only and not for use by or on behalf of any business or legal entity. HUMBL may use the Automated Clearing House ("ACH") network, electronic funds transfer, or other methods to process transactions relating to an Account.HUMBL is not responsible for actions taken by an Account Provider, such as improperly posting a transaction.
MAKE SURE THE ACCOUNT NUMBER,ACCOUNT PROVIDER DETAILS, AND CURRENCY SELECTED ARE CORRECT BEFORE SENDING. IFTHE ACCOUNT NUMBER OR ACCOUNT PROVIDER DETAILS ARE INCORRECT, MONEY MAY BE DEBITED OR CREDITED TO THE WRONG ACCOUNT AND MAY NOT BE RECOVERED.
d. Transfers to Accounts
Receiver's agreement with theAccount Provider governs Receiver's rights, liabilities and fees (including fees to transfer funds out of an Account), and the Account Provider may impose its own restrictions regarding funds availability, limits that may be transferred to or held in an Account, hours of operations, holidays or other limitations. In most cases, Receiver must have an active account to receive such a transfer. A Receiver who is not have an active account may be able to receive funds at a HUMBL HUB Agent location and may be subject to additional requirements. HUMBL may make money from fees associated with use of Accounts.
e. Transfers from Accounts
By initiating a transaction from anAccount (an "Account Funded Transaction"), You affirm You are the owner of the Account and have authority to initiate the transaction and authorize HUMBL to initiate electronic debits and credits to Your Account to process and correct errors or if a transaction cannot be completed. HUMBL may by law be liable for damages caused by its failure to debit Your Account in accordance with these terms and conditions, in the correct amount or in a timely manner when properly instructed by You. However, HUMBL will not be liable where: (A) You do not have available funds in Your Account; (B) YourAccount is closed or withdrawals restricted; (C) the transaction exceeds dollar or frequency limitations imposed by YourAccount Provider or HUMBL; (D) circumstances beyond HUMBL's control (such as flood, fire, power outages, mechanical or system failures); (E) Your AccountProvider does not honor a transaction, the transaction is not processed or the transaction is returned by Your Account Provider; (F) Your instructions are lost or delayed in transmission to HUMBL; (G) HUMBL fails to process your transaction because of a reasonable security concern or the Service option has been discontinued or suspended, or HUMBL otherwise advises You that Your request will not be processed; and (H) other exceptions allowed by law.
4. Privacy
HUMBL takes the privacy of its users seriously. HUMBL’s Privacy Policy provides a summary of HUMBL’s practices relating to the collection, sharing and use of your personal information. You represent and warrant that you have read the Privacy Policy before providing any of your personal information to HUMBL.
5. General Use and Prohibited Use
a. Conditions and Restrictions
HUMBL may, in its sole discretion and without prior notice, impose conditions, restrictions or limitations on any user’s use of or access to the Services including by:
· Refusing to open a HUMBL Account;
· Limiting the number of HUMBL Accounts that you hold;
· Suspending or terminating any HUMBLAccount;
· Suspending or terminating trading activity in your HUMBL Account or initiated, performed or executed using your HUMBLUser ID;
· Refusing to process, or to cancel or reverse, any transaction submitted via theServices; or
· Imposing limits on the transaction amounts permitted via the Services.
Such limitations and restrictions may result from, among other things, investigations by HUMBL into your or any other user’s accessing or use of theServices.
You understand further that HUMBL’s third-party providers may limit or restrict your access to their services, which would therefore limit your ability to transact on HUMBL. HUMBL has the right to review the transactions and any other activity in which you engage while using the Services.
b. Security
HUMBL takes the security of its users seriously: HUMBL imposes significant security measures to protect your HUMBL Account and User Information, and we expect you to do the same. It is critical to protect not only your password and any other security measures you use, but also the email account associated with your HUMBL Account and any device used to access your HUMBLAccount.
You acknowledge and agree that you are responsible for maintaining the confidentiality and security of your HUMBL Account, including your HUMBL User ID, password and any other security feature that you use to access the Services. You agree to notify HUMBL immediately if you become aware of any unauthorized use of the Services or any other breach of security regarding the Services. HUMBL will not be liable for any loss or damage arising from your failure to protect your HUMBL Account or your personal user or security information.
You agree that HUMBL is not liable for any damage or interruptions caused by any computer viruses, spyware, or other malware that may affect your computer or other equipment, or any phishing, spoofing, or other attack. You agree not to transmit any worms, viruses, or other destructive codes onto any HUMBL site, app, or service.
c. Compliance with Laws & Taxes
You alone are responsible for complying with all applicable laws related to your transactional activities and other use of the Services, including without limitation any reporting obligations and payment of all applicable taxes. In addition, you are responsible for determining, remitting, withholding, filing, and reporting all taxes, duties, and other governmental assessments associated with your activity in connection with the Services.
d. AML/KYCCompliance
HUMBL maintains an internal AML and know your customer (“KYC”) compliance program (“AML/KYC Program”). HUMBL’s AML/KYC Program may be updated from time-to-time, including the procedures that HUMBL uses to verify its users’ identities. HUMBL may be required to file details of account activity with FinCEN, or to provide information to other government agencies as required by law.
e. Relationship of the Parties
HUMBL is an independent contractor for all purposes. Nothing in these Terms shall be deemed to create or constitute, imply, give effect to or otherwise recognize a partnership, employment, joint venture, or formal business relationship of any kind. HUMBL is not your bank, intermediary, agent or advisor, and has no fiduciary relationship, duty or obligation to you or any other user in connection with your use of the Services. Neither HUMBL nor its licensors or suppliers are providing tax advice, legal advice, or other professional advice by allowing you to use the Services.
f. Unclaimed Property
If HUMBL is holding funds in your HUMBLAccount, and HUMBL is unable to contact you and has no record of your use of the Services for several years, applicable law may require HUMBL to report these funds as unclaimed property to the applicable jurisdiction. If this occurs, HUMBL will try to locate you at the address shown in our records, but if HUMBL is unable to locate you, it may be required to deliver any such funds to the applicable state or jurisdiction as unclaimed property.
g. Prohibited Use
You are prohibited from accessing or using the Services, or registering for a HUMBLAccount, if you:
i. Have been identified as a “Specially Designated National” by the Office of ForeignAssets Control;
ii. Have been placed on the U.S. Commerce Department’s Denied Persons List;
iii. Are located in, under the control of, or a national, citizen or resident of any RestrictedLocations (as defined below), or any country to which the United States has embargoed goods or services.
You represent, warrant, and agree that you will not use or interact with theServices, including by contributing any Content or User Information (as those terms are defined herein), in a manner that:
iv. Violates any law, rule or regulation, including, without limitation, any applicable export control laws, any unlawful trading practices (e.g., spoofing, wash trades, front running, layering, creation of fictitious trades, etc.), and any unlawful internet gambling;
v. Infringes or violates the intellectual property rights or any other rights of anyone else(including HUMBL);
vi. Is harmful, fraudulent, deceptive, threatening, harassing, defamatory, obscene, or otherwise objectionable in HUMBL’s sole discretion;
vii. Jeopardizes the security of your HUMBL Account or any other user’s HUMBL Account (such as allowing someone else to log in to the Services as you);
viii. Attempts, in any manner, to obtain the password, account, or other security information from the HUMBL Account of any other user;
ix. Violates the security of any computer network, including any attempts to hack users’ passwords or security encryption codes;
x. Runs Maillist, Listserv, any form of auto-responder or “spam” on the Services, or any processes that run or are activated while you are not logged into theServices, or that otherwise interfere with the proper working of the Services(including by placing an unreasonable load on the Services’ infrastructure);
xi. “Crawls,”“scrapes,” or “spiders” any page, data, or portion of or relating to theServices or Content (through use of manual or automated means);
xii. Copies or stores any significant portion of the Content;
xiii. Decompiles, reverse engineers, or otherwise attempts to obtain the source code or underlying information of or relating to the Services;
xiv. Brings disrepute to, or otherwise harms the reputation of, HUMBL or any of its affiliates or service providers; or
xv. Uses any information or other knowledge gained through use of the Services to provoke an interference with any patent application which HUMBL has filed with respect to the Services, or to amend any claim in any pending patent applications to expand such claim to read on, cover or dominate any invention(whether or not patentable) relating to the Services.
You are further prohibited from using the Services in any manner that is not expressly and unambiguously authorized by these Terms.
6. ProprietaryContent
a. Service Content
The Site, and each of its modules, together with the arrangement and compilation of the content found on this Site, is the copyrighted property of HUMBL and/or its various affiliates, subsidiaries, and where intended, third party providers and distributors. In addition, the trademarks, logos, and service marks displayed on this Site are registered and common law trademarks, logos, and/or service marks of HUMBL, its affiliates, subsidiaries, and various third parties.Nothing contained on this Site should be construed as granting, by implication, estoppel or otherwise, any license or right to use any of the trademarks, logos and/or service marks without the prior written permission of HUMBL, or such other party that may own the trademarks, logos, and/or service marks.
TheServices are proprietary to HUMBL. Any materials displayed or performed or available on or through the Services, including but not limited to, text, graphics, data, articles, photos, images, illustrations (all of the foregoing, the “Content”) are protected by copyright and/or other intellectual property laws.
You represent and warrant that you will not use, copy, reproduce, modify, translate, publish, broadcast, transmit, distribute, perform, upload, display, license, sell, commercialize or otherwise exploit for any purpose any Content not owned by you, without the prior consent of the owner of that Content, or in a way that violates HUMBL’s rights or the rights of any other third party.
You agree not to modify, publish, transmit, participate in the transfer or sale of, reproduce, create derivative works based on, or otherwise exploit any of theServices.
You acknowledge and agree that HUMBL transfers no ownership or intellectual property interest or title in and to the Content or the Services to you or anyone else in connection with your use of the Services.
HUMBL may, in its sole discretion, remove any Content from the Services at any time, for any or no reason and without notice. HUMBL may, from time to time, monitor and review any information transmitted or received through this Site, and reserves the right to sensor, edit, remove, or prohibit the transmission or receipt of any information that HUMBL deems inappropriate or in violation of these terms and conditions. During monitoring, the information may be examined, recorded or copied, and your use of this Site constitutes your consent to such monitoring and review.
b. Limited License
Subject to your continued compliance with these Terms, HUMBL provides to you a revocable, limited, non-exclusive, non-transferable, and non-sublicensable license to access and use the Services, and related content, materials and information. The license granted herein automatically terminates upon HUMBL’s suspension or termination of your HUMBL Account or your ability to access or use the Services, or upon your cancellation of your HUMBLAccount.
All rights not expressly granted under these Terms are hereby reserved.
c. User Content
HUMBL may offer you the ability to post, upload, share, store, or otherwise provide information, text, images, data, content or other materials through theServices (collectively, “User Information”). Some User Information may be viewable by other users, and presented in an aggregated and anonymized format.
Pursuant to these Terms, you grant HUMBL a royalty-free, non-exclusive, non-fully paid-up, sublicensable, transferable, perpetual, irrevocable, non-exclusive, worldwide license to use, copy, modify, create derivative works of, display, perform, publish and distribute, in any form, medium or manner, any UserInformation. You represent and warrant that: (i) you own the UserInformation or have the right to grant the rights and licenses in these Terms, and (ii) HUMBL’s use of the User Information as licensed herein does not and will not violate, misappropriate or infringe on the rights of any third party.
You understand and agree that HUMBL, in performing the required technical steps to provide the Services to users(including you), may need to make changes to your User Information to conform and adapt that User Information to the technical requirements of connection networks, devices, services, or media, and the foregoing licenses include the rights to do so.
HUMBL, at its sole discretion, may remove any User Content from any of the Services at any time for any or no reason.
d. Public User Information
You acknowledge and agree that any materials, including any feedback, suggestions, improvements, enhancements, feature requests, ideas, notes, drawings or other information or commentary you provide via the Services or the HUMBL App (collectively, “Public UserInformation”), that you provide to HUMBL, whether by email, posting to any HUMBL-related website, provided via the HUMBL app or otherwise, are non-confidential and will become the sole property of HUMBL.
You grant HUMBL the licenses listed in section 8(c) of the Terms, as well as a license to display, perform, and distribute your Public User Information for the purpose of making that Public User Information accessible to all HUMBL users and providing the Services necessary to do so, as well as all other rights necessary to use and exercise all rights in the Public User Information in connection with the Services and/or otherwise in connection with HUMBL’s business for any purpose.
e. Third Party Content
The Services may contain links or connections to third party websites, applications, services or other materials (“Third Party Content”) that are not owned or controlled by HUMBL. You accept and acknowledge the risks of accessing any Third-Party Content, and that HUMBL has no control over and assumes no responsibility for and cannot monitor, verify, censor or edit any Third-Party Content.
You expressly waive as against HUMBL, and HUMBL expressly disclaims, any liability, losses or damages arising from your accessing or incurred as a result of any actions taken in reliance on any Third-Party Content. The ability to access any Third-Party Content through the Services does not constitute an endorsement by HUMBL of any product, service or information.
We encourage you to be aware when you leave the Services, and to read the terms and conditions and investigate the source of any Third-Party Content that you visit or use.
7. Services
TheServices and funds availability are subject to certain factors and restrictions, including the destination country, regulatory issues, service selected, amount sent, currency availability, delivery restrictions, consumer protection issues, identification requirements, agent location hours, and differences in time zones (collectively, "Restrictions").
For users accessing HUMBL HUB and HUMBL Mobile Payment Services, the designated recipient ("Receiver") may generally receive funds sent by HUMBL consumers("You") at HUMBL HUB Agent locations in the designated payout location.For transactions sent within the U.S., the designated payout location generally means any HUMBL HUB Agent location in the destination state or U.S. territoryYou identify. For transactions sent outside the U.S., designated payout location generally means any HUMBL HUB Agent location in the destination country You identify. You may pay for the Services by using a U.S. issued Visa orMasterCard credit card, or debit card issued by or through a financial institution located in the U.S. ("Bank Card"). Alternatively, you may pay with cash at select HUMBL HUBS agent locations that accept cash or by usingHUMBL's mobile app, or ACH options ("Alternative Payment Options")where available. The total due is payable before a HUMBL HUB or HUMBL MobilePayment can process the transaction. If HUMBL does not receive authorization from the Bank Card issuer (or your account provider, in the case of AlternativePayment Options), the transaction will not be processed and funds will not be transmitted to the Receiver. Each time You use your Bank Card or AlternativePayment Options to pay for Services, you agree that the HUMBL HUB or HUMBLMobile Payment App is authorized to charge Your applicable account or designated Bank Card or for the total disclosed to You relating to the transaction. Receiver will normally receive funds sent by You in cash, HUMBLMobile wallet, or a combination thereof; with some Services, funds may be credited to a bank, prepaid or credit card, mobile wallet, or similar account.Receiver may have the option to elect a payout method that differs from the payout method You specify depending on the destination country and regulatory restrictions; You authorize HUMBL HUBS or HUMBL Mobile APP to honor Receiver's election of payout method. Receivers who choose to receive funds through a payout method other than cash or in a currency other than the one You selected may incur additional fees to access funds. Certain countries and/or jurisdictions may impose a tax, fee and/or tariff on Your transaction and/ orReceiver's receipt of, or access to, transferred funds. Transactions which exceed certain amounts to certain destinations, that implicate certain regulatory issues or consumer protection issues, or are sent through delayed options may take longer, be subject to dollar limits or be subject to additional restrictions. Certain transactions may be reported to applicable authorities. In certain destinations the Receiver may be required to provide identification and answer a test question or both to receive funds in cash.Test questions are prohibited in certain countries, and test questions are not an additional security feature and cannot be used to time or delay the payment of a transaction. HUMBL HUBS and HUMBLMobile App relies on the information you provide us to send money. Please review all transaction details for accuracy before completing your transaction.
8.Transactions
a. Funding Your HUMBL Account
To begin using your HUMBL Account, you must transfer funds to your HUMBL Account.
In order to be enabled to transact in currency on HUMBL, you must complete certain KYC/AML requirements.
To fund your e-Wallet, you must first link an approved external bank account, and then authorize HUMBL’sCustodian to debit funds from the external bank account that you designate to link to the HUMBL platform. After you have provided such authorization, you may transfer funds to your e-Wallet. Alternatively, you may instruct your external financial institution to wire funds directly to the Custodian.
You may make deposits to your e- Wallet periodically and at your discretion, but you acknowledge and agree that it is solely your responsibility to ensure there are sufficient funds in your HUMBL Account to (i) engage in any transactions you execute with your HUMBL Account or your credentials; and (ii) pay any transactional or other fees associated with your HUMBL Account.
You represent and warrant that all funds transferred into your HUMBLAccount are not the direct or indirect proceeds of any criminal or fraudulent activity.
b. Withdrawals
You may withdraw currency from your HUMBL Account. HUMBL may, in its sole discretion, impose limits on the amounts that you are able to withdraw from your HUMBL Account on a daily or other periodic basis.
c. Fees
HUMBL charges certain fees for access to or use of theServices. Detailed information about these fees is available on our Fees page [hyperlink]. Our fees may change from time to time, so you should review the Fees Page periodically.
By using the Services, you agree to pay HUMBL any and all applicable fees, and to maintain a sufficient balance in your HUMBL Account to meet any relevant fees. You authorize HUMBL to charge or deduct any applicable fees from your HUMBL Account.
d. Transaction History
Your transaction history is available through the Services and will show all of your transactional activity, including pending transactions, deposits and withdrawals, as well as the balances in your e-Wallet. HUMBL will use commercially reasonable efforts to ensure that the information contained in your transaction history is accurate. Any transaction listed in your transaction history or otherwise communicated to you by HUMBL will be deemed to be valid and correct unless you provide written notice to HUMBL Customer Support at support@humbl.io within three (3) days of the transaction.
Nothing in your transaction history shall be deemed a valuation by HUMBL, or any other third party.
e. Unauthorized Transactions
When a transaction occurs using yourHUMBL User ID or your HUMBL Account, we will assume that you authorized such transaction, unless you notify us otherwise. If you believe you did not authorize a particular transaction or that a transaction was incorrectly executed, you must contact HUMBL Customer Support as soon as possible either via email at support@humbl.io. It is important that you regularly check your transaction history as well as the balances in your e-Wallet to ensure you notify us of any unauthorized or incorrect transactions.
You acknowledge and agree that HUMBLis not responsible for any claim for unauthorized or incorrect transactions unless you have notified us in accordance with this section.
f. Electronic Fund Transfer Disclosure Statement
The following disclosures are made in accordance with the federal law regarding electronic payments, deposits, transfers of funds and other electronic transfers to and from your account(s). There may be limitations on account activity that restrict your ability to make electronic fund transfers. Any such limits are disclosed in the appropriate agreements governing your HUMBL Account. This disclosure statement may not apply to you if you do not transact with fiat currency on HUMBL.
g. International Transfers & Currency Exchange
Subject to applicable laws, international transfers may be canceled for a full refund of the principal and fees paid within 30 minutes of payment, unless the funds have been picked up or deposited. You may also receive a full refund in certain circumstances if you successfully assert an error or as otherwise provided under applicable law.
In addition to the transfer fees applicable to this transaction, a currency exchange rate will be applied.United States currency is converted to foreign currency at an exchange rate set by HUMBL unless the laws of the designated payout location do not permit HUMBL to set an exchange rate. Any difference between the rate given to You and the ate received by HUMBL will be kept by HUMBL (and its HUB Agents in some cases)in addition to the transfer fees. Subject to applicable law, the actual or estimated currency exchange rate applicable to Your transaction will be provided to You on the written disclosures provided to You by HUMBL in connection with Your transaction. Payouts will generally be made in the national currency of the designated payout location ("LocalCurrency"). In some countries, You may designate a payout currency other than the Local Currency; however, the alternate currency You choose may not be available at all Agent locations. HUMBL is not responsible for the currency exchange rate that will be applied if Receiver chooses to receive a currency other than the currency You selected.
h. Refunds
Subject to applicable law:(i) transfers may be canceled for a refund of the principal amount, unless the funds have been picked up or deposited at the time HUMBL receives Your written request; (ii) for certain services, excluding HUMBL's prepaid products and services, HUMBL may provide a transfer fee refund if funds are not available within the specified timeframe; and HUMBL may charge You a fee to refund the principal amount back to You in those instances where Receiver rejects Your funds. Qualifying refunds for transfers that begin and end in the United States will be made within 45 days of receipt of Your valid written request. HUMBL may issue Your refund through a refund to the credit or debit card that was used to pay for the transaction. In lieu of receiving the refund by credit or debit card, You may request HUMBL to mail You a check in the amount of the refund.Where required by law, refunds associated with certain international transfers may be eligible for different treatment.
The following provision applies only to transactions from California:
RIGHT TO REFUND: "You, the customer, are entitled to a refund of the money to be transmitted as the result of this agreement if HUMBL does not forward the money received from You within 10 days of the date of its receipt, or does not give instructions committing an equivalent amount of money to the person designated by You within10 days of the date of the receipt of the funds from You unless otherwise instructed by You. If Your instructions as to when the moneys shall be forwarded or transmitted are not complied with and the money has not yet been forwarded or transmitted You have a right to a refund of Your money. If You want a refund, You must mail or deliver Your written request to HUMBL LLC(insert address). If You do not receive Your refund, You may be entitled toYour money back plus a penalty of up to $1,000 and attorney's fees pursuant toSection 2102 of the California Financial Code."
Definitions:
An “Electronic Fund Transfer”is any transfer of funds, other than a transaction originated by check, draft or similar paper instrument, that is initiated through an electronic device or computer to instruct us to debit or credit an account. Electronic Fund Transfers include such electronic transactions as direct deposits or withdrawals of funds, transfers initiated via telephone, website or mobile application.
A “Preauthorized ElectronicFund Transfer” is an Electronic Fund Transfer that you have authorized in advance to recur at substantially regular intervals; for example, direct deposits into or withdrawal of funds out of your account.
Your Liability:
Authorized Transfers:You are liable for all Electronic Fund Transfers that you authorize, whether directly or indirectly.
Unauthorized Transfers:If you believe your HUMBL Account or HUMBL User ID or other identifying information has been lost or stolen or has been or may be subject to unauthorized Electronic Fund Transfers, you must inform HUMBL immediately to keep your possible losses to a minimum. You could lose all the money in your HUMBLAccount. To report a complaint relating to the bank services, email support@humbl.io.
9. Cancellations
You may only cancel a transaction initiated via the Services if such cancellation occurs before your transaction has cleared. HUMBL reserves the right to refuse any cancellation request associated with a transaction after submission.
If you have insufficient funds to support a transaction, HUMBL may cancel the transactions after deducting any fees payable to HUMBL.
10. Account Suspension, Termination or Closure
HUMBL may, in its sole discretion and without notice, terminate or suspend your HUMBLAccount or your access to or use of the Services at any time, for any reason, including breach of these Terms or of any HUMBL Policy.
You may close your HUMBL Account or cease using the Services at any time. To close your HUMBL Account, you must contact us at support@humbl.io.
We encourage you to withdraw any remaining balance from your HUMBL Account prior to issuing a request to close your account. We will be unable to close your account at your request unless you have withdrawn any remaining balances in your HUMBL Account. We reserve the right to restrict or refuse to permit withdrawals from your HUMBL Account if(a) HUMBL has already suspended or terminated your HUMBL Account pursuant to these Terms; (b) to do so would be prohibited by law or a court order or we suspect that your HUMBL Account is connected to fraudulent activity; or (c) you have not undergone the required identity verification procedure.
Account termination may result in destruction of any Content or User Information associated with your HUMBL Account.
11. Electronic Delivery of Communication
You agree and consent to receive electronically all communications from HUMBL, including those communications relating to the Services or to your HUMBLAccount. You agree that HUMBL may provide these communications to you by posting them via the Services, emailing them to you at the email address you provide to HUMBL, and/orby sending an SMS or text message to the mobile phone number you provide to HUMBL.
It is your responsibility to provideHUMBL with your accurate email address, your contract information and/or mobile phone number, and to update such information with HUMBL. If HUMBL sends you an electronic communication but you do not receive it because your contact information on file is incorrect, or you are otherwise unable to receive electronic communications, HUMBL will be deemed to have provided the communication to you.
By agreeing to the Terms, you also agree to receive any communications from NIUM electronically.
All communications from HUMBL in electronic format will be deemed to be “in writing,” and to have been received within twenty-four (24) hours after posting or dissemination.
You may decline or withdraw consent to receive communications electronically from HUMBL, but you agree and acknowledge that HUMBL may suspend or terminate your use of the Services if you do not consent to receive communications in electronic format.
12. Indemnification and Release
You agree to indemnify and hold harmless HUMBL, its affiliates, officers, agents, employees, contractors, licensors and partners from and against any and all claims, actions, proceedings, investigations, liabilities, costs, damages(actual and consequential), losses and expenses (including attorneys’ fees)arising from or in any way related to (a) your use of, or conduct in connection with, the Services (including any actions taken by a third party using your HUMBLAccount or HUMBL User ID); (b) your violation of these Terms; or (c)your violation of any applicable law, regulation, or rights of any third party.
If you are obligated to indemnify HUMBL or any of the indemnified parties identified above, HUMBL (or, at HUMBL’s discretion, the applicable indemnified party) will have the right, in its sole discretion, to control any action or proceeding and to determine whether HUMBL wishes to settle, and if so, on what terms.
If you are a California resident, you waive California Civil Code Section 1542, which states:
“A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE CREDITOR DOES NOT KNOW OR SUSPECT TO EXIST IN HIS OR HER FAVOR AT THE TIME OF EXECUTIVE THE RELEASE,WHICH IF KNOWN BY HIM OR HER MUST HAVE MATERIALLY HIS OR HER SETTLEMENT WITH THE DEBTOR.”
If you are a resident of another jurisdiction, you waive any comparable statute or doctrine.
13. Disclaimer of Warranties
None of HUMBL, its licensors, partners, suppliers or service providers make any representations or warranties concerning any Content or other material contained in or accessed through the Services, and we will not be responsible or liable for the accuracy, copyright compliance, legality, or decency of material contained in or accessed through the Services. HUMBL will have no liability or responsibility for any permanent or temporary inability to access or use any Services.
TOTHE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, THE SERVICES AND CONTENT ARE PROVIDED BY HUMBL (AND ITS LICENSORS AND SUPPLIERS) ON AN “AS-IS” BASIS, AND HUMBL DISCLAIMS, AND YOU WAIVE, ANY AND ALL OTHER WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING, WITHOUT LIMITATION, IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, THAT HUMBL WILL PROCESS A TRANSACTION PROPERLY OR THAT USE OF THE SERVICES WILL BE UNINTERRUPTED OR ERROR-FREE. YOU ACKNOWLEDGE THAT THERE ARE RISKS ASSOCIATED WITH UTILIZING AN INTERNET-BASED FINANCIAL SYSTEM, INCLUDING WITHOUT LIMITATION, THE FAILURE OF HARDWARE, SOFTWARE AND INTERNET OR OTHER NETWORK CONNECTIONS AND THAT HUMBL SHALL NOT BE RESPONSIBLE FOR ANY FAILURES, ERRORS, DISTORTIONS OR DELAYS YOU MAY EXPERIENCE WHEN USING THE SERVICES, REGARDLESS OF THE CAUSE. YOU ACKNOWLEDGE THAT INFORMATION YOU STORE OR TRANSFER THROUGH THE SERVICES MAY BECOME IRRETRIEVABLY LOST OR CORRUPTED OR TEMPORARILY UNAVAILABLE DUE TO A VARIETY OF CAUSES, INCLUDING SOFTWARE FAILURES, PROTOCOL CHANGES BY THIRD PARTY PROVIDERS, INTERNET OUTAGES, FORCE MAJEURE EVENT OR OTHER DISASTERS INCLUDING THIRD PARTY ATTACKS, SCHEDULED OR UNSCHEDULED MAINTENANCE OR OTHER CAUSES EITHER WITHIN OR OUTSIDE OUR CONTROL. YOU ARE SOLELY RESPONSIBLE FOR BACKING UP AND MAINTAINING DUPLICATE COPIES OF ANY INFORMATION YOU STORE OR TRANSFER THROUGH THE SERVICES.
THE DISCLAIMER OF WARRANTIES CONTAINED HEREIN MAY NOT APPLY IF AND TO THE EXTENT ITIS PROHIBITED BY APPLICABLE LAW OF THE JURISDICTION IN WHICH YOU RESIDE.
14. Limitation of Liability
TOTHE FULLEST EXTENT ALLOWED BY APPLICABLE LAW, IN NO EVENT AND UNDER NO LEGAL THEORY (INCLUDING, WITHOUT LIMITATION, TORT, CONTRACT, STRICT LIABILITY, OR OTHERWISE) SHALL HUMBL, ITS LICENSORS, SUPPLIERS, AFFILIATES AND SERVICE PROVIDERS, OR ANY OF THEIR RESPECTIVE OFFICERS, DIRECTORS, AGENTS,JOINT VENTURERS, EMPLOYEES OR REPRESENTATIVES BE LIABLE TO YOU OR TO ANY OTHER PERSON FOR (A) ANY INDIRECT, SPECIAL, INCIDENTAL, OR CONSEQUENTIAL OR SIMILAR DAMAGES, INCLUDING DAMAGES FOR LOST PROFITS, LOSS OF GOODWILL, LOSS OF DATA, WORK STOPPAGE,ACCURACY OF RESULTS, OR COMPUTER FAILURE OR MALFUNCTION ARISING OUT OF OR RELATED TO THE TERMS, YOUR USE OR ATTEMPTED USE OF HUMBL, ANY OF THE SERVICES(AS DEFINED ABOVE), OR ANY OF THE OTHER INFORMATION, SERVICES OR TRANSACTIONS CONTEMPLATED BY THESE TERMS, OR (B) ANY AMOUNT, IN THE AGGREGATE, IN EXCESS OFTHE FEES PAID BY YOU TO HUMBL IN CONNECTION WITH THE SERVICES IN THE THREE (3)MONTH PERIOD PRECEDING THE APPLICABLE CLAIM.
SOME STATES DO NOT ALLOW THE EXCLUSION OR LIMITATION OF CERTAIN DAMAGES, SO THE ABOVE LIMITATION AND EXCLUSIONS MAY NOT APPLY TO YOU.
15. Dispute Resolution
a. Initial Dispute Process
If you have a complaint against or dispute with HUMBL, you agree to notify HUMBL first through HUMBL Customer Support at support@humbl.io to attempt to resolve the dispute. Within fifteen (15) business days of HUMBL Customer Support receiving a Complaint, a HUMBL representative will contact you at the email address that you have provided as associated with yourHUMBL Account to inform you of HUMBL’s determination regarding the validity of your complaint; and how, if at all, HUMBL is willing to resolve your complaint(the “HUMBL Resolution”). In the alternative, HUMBL may request a formal written explanation of any dispute (a“Written Complaint”) after reviewing your initial Complaint, and before providing a HUMBL Resolution. Within 20days of receiving a Written Complaint, a HUMBL representative will contact you via email to inform you of the HUMBL Resolution.
If HUMBLis unable to respond to you within the specified timelines, a HUMBL representative will contact you via email to inform you of the deadline by which HUMBL will respond to you.
You agree to engage in this informal dispute resolution process before filing any arbitration claim. If you do not provide a Complaint or engage in this initial dispute resolution process prior to filing an arbitration, HUMBL shall have the right to request that the arbitrator dismiss your filing unless and until we engage in the process described in this section.
b. Arbitration Agreement
Please read the following ARBITRATION AGREEMENT carefully because it requires you to arbitrate ALL disputes with HUMBL and limits the manner in which you can seek relief.
You and we acknowledge and agree that any controversy, claim or dispute arising out of or relating to the subject matter of these Terms or to the Services, including, without limitation, federal and state statutory claims, common law claims, and those based in contract, tort, fraud, misrepresentation, or any other legal theory, shall be finally resolved, on an individual basis, through binding arbitration. Any arbitration shall be conducted (i) confidentially, (ii) in English, (iii) by the American Arbitration Association and Meditation (AAA), (iv) before a single arbitrator with substantial experience in resolving commercial contract disputes, and (v) in accordance with the AAA Comprehensive Dispute ResolutionRules and Procedures, available at www.adr.org.
Judgment upon the award rendered by such arbitrator may be entered in any court of competent jurisdiction. Notwithstanding the foregoing obligation to arbitrate disputes, each party shall have the right to pursue injunctive or other equitable relief at any time, from any court of competent jurisdiction.
Any dispute over the arbitrability of these Terms and/or the arbitrability of any dispute shall be resolved in arbitration in accordance with this provision.
You agree that you are electing to have any and all claims and disputes between you and HUMBL resolved by binding arbitration and are giving up any rights to go to court, except as expressly provided herein. YOU ACKNOWLEDGE AND AGREE YOU AND HUMBL ARE EACH WAIVING ANY RIGHT TO A TRIAL BY JURY.
To the extent that any controversy, claim or dispute is not resolved by binding arbitration, you and HUMBL agree that any judicial proceeding will be brought in the state or federal courts located in California.
c. Class Action Waiver
TOTHE EXTENT PERMISSIBLE BY LAW, ALL CLAIMS AND DISPUTES MUST BE BROUGHT IN APARTY’S INDIVIDUAL CAPACITY, AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS, COLLECTIVE ACTION, OR REPRESENTATIVE PROCEEDING. A CLAIMANT ORTHE ARBITRATOR MAY NOT CONSOLIDATE MORE THAN ONE PERSON’S CLAIMS OR ENGAGE IN ANY CLASS ARBITRATION OR JOINT LITIGATION. CLAIMS OF MORE THAN ONE CUSTOMER OR USER CANNOT BE ARBITRATED OR LITIGATED JOINTLY, ON A CLASS BASIS OR CONSOLIDATED WITH THOSE OF ANY OTHER CUSTOMER OR USER. YOU ACKNOWLEDGE AND AGREE THAT YOU AND HUMBL ARE WAIVING ANY RIGHT TO PARTICIPATE AS A PLAINTIFF OR CLASS REPRESENTATIVE IN ANY PURPORTED CLASS ACTION OR REPRESENTATIVE PROCEEDING.
16. General Provisions
a. Governing Law
TheseTerms are governed by and will be construed under the laws of the State of California, without regard to the conflicts of laws principles, and the same will apply to any dispute that arises between you and HUMBL.
b. Entire Agreement
These Terms, including the Privacy Policy, constitute the entire agreement between you and HUMBL with respect to the subject matter hereof, including the Services. These Terms, including the Privacy Policy, supersede any and all prior or contemporaneous written and oral agreements, communications and other understandings relating to the subject matter of these Terms.
TheseTerms do not alter any agreement you have with the Custodian regarding theServices. In the event of any conflict between these Terms and any agreement with the Custodian, the terms of that other agreement will control only if these Terms are specifically identified and declared to be overridden.
c. Survival
All provisions of these Terms which by their nature extend beyond the expiration or termination of these Terms shall survive termination of your HUMBL Account. By way of example, all of the following will survive termination: any obligation you have to pay us or indemnify us, any limitations on our liability, any terms regarding ownership or intellectual property rights, and terms regarding disputes between us, including without limitation the arbitration agreement.
d. No Waiver
The failure of either you or us to exercise, in any way, any right herein shall not be deemed a waiver of any further rights hereunder.
e. Assignment
You may not assign, delegate or transfer these Terms or your rights or obligations hereunder, or your HUMBL Account, in any way (by operation of law or otherwise)without HUMBL’s prior written consent. We may transfer, assign, or delegate these Terms and our rights and obligations without consent, including as part of a change of control or other corporate combination or transaction.
You acknowledge and agree that any of HUMBL’s officers, directors, employees and independent contractors (“Personnel”) are third party beneficiaries of these Terms, and that upon your acceptance of these Terms, Personnel will have the right (and will be deemed to have accepted the right) to enforce these Terms against you as the third-party beneficiary hereof.
f. Headings
The section headings in these Terms are for convenience only and shall not govern the meaning or interpretation of any provision of these Terms.
g. Severability
If any provision of these Terms shall be determined to be unenforceable or invalid under any rule, law or regulation of any local, state or federal government, such provision will be limited, changed or eliminated only to the minimum extent necessary to accomplish the objectives of the provision to the greatest extent possible under applicable law and these Terms shall otherwise remain valid, in full force, and enforceable.
h. Force Majeure
HUMBL shall not be liable for delays, failure in performance or interruption of any of the Services which result directly or indirectly from any abnormal or unforeseeable circumstance, cause or condition beyond our reasonable control, including but not limited to, significant market volatility, any delay or failure due to any act of God, act of civil or military authorities, act of terrorists, civil disturbance, war, strike or other labor dispute, fire, interruption in telecommunications orInternet services or network provider services, failure of equipment and/or software, other catastrophe or any other occurrence which is beyond our reasonable control and shall not affect the validity and enforceability of any remaining provisions.
17. Contact
For more information about HUMBL or any of the Services, please visit our website HUMBL.com. If you have any questions, comments, or concerns regarding these Terms or the Services, please contact our Customer Support team at support@humbl.io.
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Copyright 2020 HUMBL
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LLC
$TSNP #HUMBL Code of Conduct
HUMBL, LLC (The “Company” or “HUMBL”) has adopted this Code of Conduct and Ethics in compliance with applicable laws, regulations and rules (“Laws”) to specify the values and standard of conduct expected of its employees. Employees have an obligation to adhere to all applicable Laws. In addition, it is against Company values and potentially unlawful for the Company or its employees to directly or indirectly:
-Employ any device, scheme or artifice to defraud any client or prospective client of the Company;
-Engage in any transaction, practice, or course of business which operates or would operate as a fraud or deceit upon any client or prospective client of the Company;
-Engage in any fraudulent, deceptive, or manipulative practice;
-Perform any activities they are not otherwise authorized to perform under Company policies;
-Fail to disclose and address conflicts of interests;
-Fail to notify management or the Chief Compliance Officer (“CCO”) immediately about, or attempting to settle, any client complaints on their own;
-Guarantee any digital asset or transaction to the client or the performance of a client’s investment or account;
-Sign a client’s name to any document, even if the client gives permission to do so;
-Accept money from a client as additional compensation for digital asset services offered;
-Borrow or loan money to, a client without prior consent from management and the CCO;
-Make trades for a client who has not given the Company written authority to make such trades;
-Advertise their services or those of the Company without prior approval of the Company;
-Raise money for charitable or political organizations, directly referring to an affiliation with the Company, without prior approval from the Company; and
-Become employed with another Company or serve as a director of another Company without prior approval from the Company.
In adopting this Code, the Company recognizes that it and its employees owe a duty to the Company’s client accounts and must conduct business and personal digital transactions in a manner consistent with this Code and avoid any abuse of a position of trust and responsibility. In addition, the Company and its employees must adhere to the fundamental standard that employees should not take inappropriate advantage of their positions. To the extent applicable, the following specific activities are likewise prohibited:
-Failing or refusing to furnish a client, upon reasonable request, information to which the client is entitled, or to respond to a formal written request or complaint;
-Permitting a person to open an account for another person or transact business in the account unless there is on file written authorization for the action from the person in whose name the account is carried;
-Accepting transaction instructions from a third party without first having obtained a written third-party authorization from the client;
-Borrowing money or assets from a client unless the customer is a bank, broker-dealer, an affiliate of an investment adviser, or other financial institution engaged in the business of loaning funds or pre-approved as a result of a familial relationship;
-Loaning money to a client except where the lending party is a financial institution engaged in the business of loaning funds or pre-approved as a result of a familial relationship;
-Extending, arranging for, or participating in arranging for credit to a customer;
-Misrepresenting to any client, or prospective client, the qualifications of the Company or any personnel, or misrepresenting the nature of the services being offered or fees to be charged for such service or omitting to state a material fact necessary to make the statements made regarding qualifications, services or fees, considering the circumstances under which they are made, not misleading;
-Disclosing the identity, affairs, or investments of any customer unless required by law to do so, or unless consented to by the customer; and
-Any employee compensating any customer for losses of the customer without prior written authorization of the customer and the Company.
In addition, employees must report any violations of the Code to the Company’s management and CCO.
Failure to adhere to this Code and Company’s Compliance policies and procedures may lead to discipline including additional training, penalty applied to compensation and/or termination of employment or affiliation.
The Company intends to provide training on the Code of Conduct during employee onboarding and periodically throughout the year at the discretion of the CEO/CCO. The Company’s training program will address the following topics:
-An explanation of applicable laws and regulations and rules applicable to the Company;
-The obligation to the public to observe just and equitable principles of trade;
-How to act honestly and fairly and with due skill, care and diligence in the interest of customers;
-Establishing effective internal controls;
-Disclosure of material information to customers; and
-Avoidance, proper disclosure and handling of conflicts of interest.
The Chief Compliance Officer (CCO) or designee will retain a record of attendance of each training program.
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$TSNP #HUMBL Client Complaint Handling
This Complaint Investigation Policy (the “Policy”) of HUMBL LLC (“HUMBL”) governs the Company’s intake and resolution of complaints (each, a “Complaint”) received from customers of HUMBL’s payment applications.
HUMBL receives many different types of communications from its customers, all of which are sent to HUMBL Customer Support at xxx@xxx.com. Accordingly, HUMBL will only consider certain types of customer communications to be Complaints under this Policy and subject to the “Processes and Procedures” set forth below.
The following types of written communications constitute Complaints: those communications reasonably believed to claim that a Customer sustained monetary losses or material harm due to any issue relating to the HUMBL application, including but not limited to: (a) the functionality of the HUMBL application; (b) any inaccuracies, errors or irregularities in a transaction on the HUMBL application (each, a “Transaction”) or HUMBL’s failure to cancel a Transaction; (c) suspension or termination of a Customer HUMBL account with no explanation provided; (d) HUMBL’s decisions about any currencies supported on the HUMBL application; (e) unauthorized use of a Customer’s HUMBL Customer ID or account; or (f) actions or conduct by any third party provider to Customers of the HUMBL application. Complaints do not include operational inquiries or help desk tickets.
In addition to the types of Complaints listed above, any communications to HUMBL providing notice of a complaint filed by a Customer with any state or federal consumer protection or law enforcement agency constitutes a Complaint hereunder.
Customers may allege monetary losses relating to technological issues on the HUMBL application or problems with identity verification, such as anti-money laundering (“AML”) or “Know Your Customer” (“KYC”) procedures. Such matters are subject to other policies and procedures set forth in this manual; however, the Chief Compliance Officer (“CCO”) and the General Counsel will liaise on any such issues and will include the Chief Technology Officer (“CTO”) where necessary, to ensure that all relevant policies are adhered to for any such Complaints. Any Customer grievances submitted to HUMBL as a result of a fraud, KYC or AML investigation are subject to other policies and procedures set forth in this manual and will not be considered Complaints as defined herein.
HUMBL personnel will adhere to this Policy for all incoming Complaints, unless otherwise explicitly instructed by HUMBL’s General Counsel in consultation with HUMBL’s CCO. In addition, HUMBL personnel will adhere to the Terms of Use (the “Terms”) in addressing any Complaint.
HUMBL takes Customer Complaints seriously, and HUMBL personnel will work to address and, if possible, to resolve any Complaints in accordance with the Procedures set forth below.
If at any time HUMBL personnel handling a Complaint have questions or concerns about a Complaint, they will consult with HUMBL’s General Counsel to ensure proper compliance with this Policy.
Procedures for Resolution of Complaints
Receipt of Complaints.
HUMBL’s Terms, available at xxxx.com set forth the manner in which a Customer must submit a Complaint. Pursuant to the Terms, Customers must submit a complaint form to HUMBL Customer Support at xxx@xxx.com. (Any capitalized term not otherwise defined in these Procedures has the same meaning as set forth in the Terms.)
That requirement notwithstanding, it is possible that a Customer may submit a Complaint through a variety of channels, including, but not limited to, (a) via email to HUMBL Customer Support at xxx@xxx.com; (b) by phone to HUMBL Customer Support at xxx-xxx-xxxx; (c) by mail; and/or (d) through a HUMBL agent for service of legal documents.
For any Complaint received, all of these Procedures set forth herein will apply. HUMBL personnel responsible for Complaints may be required to employ additional procedures to a particular Complaint depending, for example, on the subject matter of the Complaint, the manner in which or the stage at which the Complaint is received.
HUMBL will designate an employee to be responsible for performing the intake and investigation of all incoming Customer Complaints. HUMBL employees and relevant contractors will be informed of the designated individual handling incoming Customer Complaints. If HUMBL changes such designated individual, it shall promptly inform relevant personnel—employees and relevant independent contractors.
The Customer Complaint Log.
For purposes of resolving all Customer Complaints, HUMBL has established a log to record Complaints received—again, regardless of the channel through which the Complaint is received—and the processes, procedures and internal investigations employed or conducted by HUMBL in resolving such Complaints (the “Complaint Log”). The Complaint Log will be a shared document among Compliance, Operations and Legal.
Upon receipt of a Complaint, the HUMBL employee designated to intake incoming complaints (“Ops personnel”) must record receipt of the Complaint in the Complaint Log. For each Complaint, Ops personnel intaking the Complaint must record the following known information:
the HUMBL Account or HUMBL Customer ID or other identifying information associated with the Complaint;
the source or channel from which the Complaint was received;
the date and time of receipt of the Complaint;
the nature of the Complaint; and
the anticipated due date for a response to the Complaint.
All entries in the Complaint Log must be factual and complete, but should not include opinion, speculation, or other commentary.
Timeline for Resolving Complaints.
HUMBL’s Terms expressly set forth the timeline for addressing any Customer Complaints. Specifically, the Terms state:
If you have a complaint against or dispute with HUMBL, you agree to notify HUMBL first through HUMBL Customer Support at support@HUMBL.com to attempt to resolve the dispute by providing the form available here (a “Complaint”). Within fifteen (15) business days of HUMBL Customer Support receiving a Complaint, a HUMBL representative will contact you at the email address that you have provided as associated with your HUMBL Account to inform you of HUMBL’s determination regarding the validity of your complaint; and how, if at all, HUMBL is willing to resolve your complaint (the “HUMBL Resolution”). In the alternative, HUMBL may request a formal written explanation of any dispute (a “Written Complaint”) after reviewing your initial Complaint, and before providing a HUMBL Resolution. Within 20 days of receiving a Written Complaint, a HUMBL representative will contact you via email to inform you of the HUMBL Resolution.
Accordingly, upon receipt of a Complaint from a Customer—regardless of the channel through which the Complaint is received—HUMBL must:
Contact the complaining Customer within 15 business days of receiving a Complaint to acknowledge the grievance and when practical inform the Customer of HUMBL’s determination regarding the validity of the complaint and proposed resolution. Such contact must be made through the email address associated with the HUMBL Account for the complaining Customer; or
If Ops personnel has requested that the Customer provide a Written Complaint (as defined in the Terms), contact the complaining Customer within 20 days to acknowledge the grievance and when practical inform the Customer of HUMBL’s determination on a proposed resolution. Such contact must be made through the email address associated with the HUMBL Account for the complaining Customer.
As noted above, Ops personnel must flag Complaint response due dates in the Complaint Log to ensure sufficient time for investigating any Complaint and providing sufficient time for any additional HUMBL personnel or executives to review and approve any proposed resolution to a Complaint prior to the due date, including but not limited to the General Counsel, the CCO, or the CTO, as necessary.
In certain limited circumstances (discussed below), HUMBL’s outside litigation counsel should be notified at an early stage in the process to provide for proper handling and/or resolution of any Complaint.
As with all other steps in the informal dispute resolution process, Ops personnel must record in the Complaint Log that a Written Complaint was requested from the Customer, along with the date and reason for seeking clarification. In addition, the new deadline for response must be recorded in the Complaint Log with notification of the deadline for response sent to all necessary internal parties.
If, for any reason, it is determined that HUMBL will not be able to respond within the specified timelines, Ops Personnel must contact the Customer (after approval by the General Counsel) via email to inform the Customer of the deadline for a response, and record all relevant information in the Complaint Log including any new deadlines.
Monetary Thresholds of Customer Complaints.
Regardless of the underlying subject matter of a Complaint (the “Subject Matter”), the amount at issue—sometimes called the “amount in controversy” (referred to herein as the “Monetary Threshold”)—for any Complaint should guide the handling and resolution of any Complaint.
In the event a Complaint involves an amount of $5000 or less, Ops Personnel should promptly undertake the Intake, Investigatory and Resolution Processes (as those terms are defined herein) set forth in Part E below. No additional processes are necessary unless the subject matter of the Complaint requires notification of the General Counsel, CCO or CTO, as appropriate.
If a Complaint involves an amount greater than $5,000, Ops Personnel should first notify the General Counsel and the CCO of the Complaint by email.
The email subject line should state in substance or words: “Notification of Threshold Customer Complaint – Privileged & Confidential.” Ops Personnel should confer with the General Counsel or CCO prior to undertaking the Investigatory Process to determine whether any modifications or amendment to such process must be included given the Monetary Threshold (which should be documented in the Complaint Log). HUMBL’s General Counsel or CCO may then notify HUMBL’s designated outside litigation counsel as needed.
If a Customer Complaint does not assert a specific amount in controversy and if review of the transaction history or other relevant documentation related to the Customer who submitted the Complaint does not provide clarity as to the amount at issue and it is clear that the Customer is seeking “damages” or other compensation from HUMBL as part of the resolution of the Complaint, Ops personnel should notify the General Counsel of the Complaint after properly logging it into the Complaint Log. The email subject line should state: “Notification of Customer Complaint – No Identified Monetary Threshold – Privileged & Confidential.”
Complaint Flow: Intake, Investigatory and Resolution Procedures.
When a Complaint is received, the designated HUMBL Ops personnel handling incoming Customer Complaints must adhere to the following process (the “Intake Procedures”):
Log the Complaint in the Complaint Log;
Assess the subject matter of the Complaint and determine whether any of the General Counsel, CCO or CTO must be notified;
Assess the Monetary Threshold applicable to the Complaint;
If the amount in controversy for a Complaint meets any of the elevated Monetary Thresholds as set forth in Part D, Ops personnel should follow the procedures for notifying the General Counsel and, where relevant, the CCO.
Assess whether the Customer properly submitted the Complaint to HUMBL.
As set forth above, HUMBL’s Terms require that all Customer Complaints be submitted through the HUMBL application form via email to HUMBL Customer Support. If a Complaint is not received through this channel, HUMBL Ops personnel may require the submitting Customer to re-submit the Complaint via the appropriate form. Any due date for responding to a Complaint that must be re-submitted via the appropriate form should be calculated from the date the proper form is received—not the date the original Complaint is received.
However, Ops personnel must request that the Complaint be re-submitted through the appropriate form no later than the 15-business day due date required under the Terms for a response to a Customer Complaint. When requesting that a Customer resubmit a Complaint via the appropriate form, Ops personnel should inform the Customer in writing that the due date for HUMBL’s initial response to the Complaint will run from the date that appropriate form is received.
If HUMBL receives a Complaint through “formal” law enforcement or litigation documents—e.g., a demand for arbitration, service of a complaint filed in federal or state court or law enforcement —Ops personnel or HUMBL personnel receiving such documents should notify immediately HUMBL’s General Counsel and then wait for further instruction, if any. HUMBL personnel should never reach out to a Customer who has formally commenced litigation, arbitration or other formal legal proceedings.
Determine whether any HUMBL personnel (e.g., General Counsel, CCO, CTO) must be notified of the Complaint prior to commencing any Investigatory Procedures, per the Intake Procedures set forth above.
Investigatory Procedures
All Complaints are subject to the same initial investigatory procedures for determining the nature and validity of any Complaint (the “Investigatory Procedures”) after completion of the Intake Procedures, unless otherwise specified in writing by HUMBL’s General Counsel or outside litigation counsel.
Such Investigatory Procedures include:
Gathering the complaining Customer’s transaction history if the Complaint relates to any Transaction;
Gathering the complaining Customer’s personal identification information;
Gathering all correspondence with or relating to the complaining Customer—not just correspondence relating to the Subject Matter of the Complaint;
Reviewing the Customer’s transaction, personal identification information, and all relevant correspondence in chronological order;
Drafting a chronology or other summary document detailing the full set of facts and circumstances underlying the Complaint;
Analyzing the validity of the Customer’s Complaint based on the information gathered in the above steps of the Investigatory Procedures;
Assessing whether further explanation of the relevant dispute or issue necessitates requesting a Written Complaint from the Customer;
If appropriate for the Complaint at issue, consulting with the General Counsel, CCO or CTO throughout the Investigatory Procedures; and
Any other procedures necessary as prescribed by the General Counsel, CCO, CTO or HUMBL’s outside counsel.
Resolution Procedures
Complaints Investigated Primarily By Ops Personnel.
After engaging in the Investigatory Procedures and assuming the Complaint is not one where the Subject Matter or Monetary Threshold requires the General Counsel, CCO or CTO to engage in the Investigatory Procedures, Ops personnel should draft a proposed resolution (which will be an attachment to an email) to an initial Customer Complaint (each, a “Proposed Resolution”).
A Proposed Resolution should include as relevant:
An acknowledgement of the Customer’s submission and Subject Matter of the Complaint;
A summary of the Complaint;
A statement that HUMBL has undertaken an investigation of the facts and circumstances relating to the Complaint;
An assessment of the validity of the Complaint based upon the investigation; and
A statement of any of the following: (a) providing a proposed offer to resolve the Complaint, including but not limited to any money HUMBL is willing to remit and/or any technological or other remedial steps HUMBL will take; OR (b) requesting the Customer submit a Written Complaint as further investigation into the Subject Matter of the Complaint is necessary; OR (c) setting forth that HUMBL does not believe any remediation or other resolution is necessary and that HUMBL is closing the Investigatory Process relating to the Complaint.
Once the communication to the Customer is approved by the General Counsel, Ops personnel must enter into the Complaint Log the date and time the response was sent to the Customer—along with the email address to which the final Proposed Resolution was sent—and should upload a copy of the final Proposed Resolution and email.
If the Customer responds to the Proposed Resolution, Ops personnel must record the date and time of the response and the nature of the response, and determine if further follow up is required or if escalation to the General Counsel is warranted.
All communications with any Customer in response to a complaint (other than non-substantive correspondence, such as requesting the submission of a Complaint form) must be approved by the General Counsel before transmission to a Customer, whether by email or otherwise.
Complaints Resolved In Conjunction With the General Counsel, CCO or CTO.
For any Complaint required to be investigated in conjunction with HUMBL’s General Counsel, Ops personnel should undertake the Investigatory Procedures set forth above even though the General Counsel ultimately will address the Complaint. For Complaints concerning a Monetary Threshold greater than $25,000, the General Counsel may work on any Proposed Resolution with HUMBL’s outside counsel.
Note that, as a general matter, for any Complaint concerning a Transaction listed in a Customer’s transaction history or otherwise communicated to the Customer by HUMBL, and the Complaint was received more than 3 days after the Transaction, Ops personnel should indicate in the Proposed Resolution that, per HUMBL’s Terms, the Transaction has been deemed to be valid and correct and—unless otherwise directed by the General Counsel or the CCO—HUMBL will not take any “remedial” action in the Proposed Resolution.
In the event that Ops personnel conducting an initial investigation determines after that additional detail is required from the Customer to assess the Complaint, Ops personnel should direct the Complaint to the General Counsel with a recommendation that HUMBL seek clarification. In such case, Ops personnel, with approval from the General Counsel, may request a formal written explanation of any dispute (i.e., a “Written Complaint”) before providing a proposed resolution to the Customer.
For any Complaint relating to technological or security issues that is being investigated in conjunction with HUMBL’s CTO, any Proposed Resolution must be drafted in conjunction with and/or approved by the CTO prior to being sent to the General Counsel for approval for submission to the Customer.
For any Complaint relating to improper trading procedures, AML/KYC matters, or any other compliance procedures that is being investigated in conjunction with HUMBL’s CCO, any Proposed Resolution must be drafted in conjunction with and/or approved by the CCO prior to being sent to the General Counsel for approval for submission to the Customer.
Escalation Procedures.
Written Complaints.
If HUMBL has requested a Written Complaint from a Customer, upon receipt of such Written Complaint, Ops personnel should re-review the documentation collected during the Investigatory Procedures to determine the validity of the facts and circumstances alleged in the Written Complaint.
After undertaking that process, Ops personnel should draft a Proposed Resolution and should share such draft with the General Counsel, as well as the CCO or the CTO, as appropriate.
Additional Follow Up Matters.
If a Customer responds to any Proposed Resolution to continue negotiation or discussion of any Complaint, Ops personnel must promptly notify the General Counsel and seek guidance as to any further negotiation or correspondence with the Customer.
It is possible that HUMBL’s General Counsel may seek to consult HUMBL’s outside litigation counsel to confer about how to approach any additional follow up with a Customer regarding a Complaint. Such follow up matters may also include, as appropriate, meetings with the Customer and his/her legal counsel, further settlement negotiations seeking to resolve a Complaint, or proposed mediation.
Arbitration.
If a Complaint cannot be resolved as between HUMBL and the Customer and the Customer is not satisfied, the Customer may file for arbitration, as required by HUMBL’s Terms.
Once a Customer has commenced arbitration (or any other formal legal proceedings), no HUMBL personnel may communicate with the Customer and/or his/her legal counsel. All communications from the Customer must be escalated to the General Counsel for response either by the General Counsel in coordination with outside counsel, or by outside counsel directly in the event HUMBL requests that counsel assume the representation.
Note, of course, that HUMBL’s Terms require a Customer to attempt to resolve any complaint or dispute with HUMBL first before initiating arbitration. Per HUMBL’s Terms, HUMBL reserves the right to request that the arbitrator dismiss the Customer’s filing unless and until the Customer engages in the informal dispute resolution process described in HUMBL’s Terms (and as outlined in this Policy).
Complaints Regarding Third-Party Service Providers.
In the event a Complaint concerns services provided to HUMBL by a third party, Ops personnel—in consultation with HUMBL’s General Counsel—should inform the Customer that all complaints regarding a third-party service provider should be directed to that entity. Upon approval by the General Counsel, Ops personnel should communicate to the Customer the name and contact information for the relevant service providers.
In the event that the Complaint concerns banking services and banking software services, the Customer should be directed (after approval by the General Counsel) to contact the relevant vendors. i.e., NIUM.
As with all other complaint-related communications with Customers, all such contacts must be recorded in the Complaint Log.
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$TSNP #HUMBL AML / CFT Policy
1. Company Overview
HUMBL LLC. (”Humbl” or the “Company”) is a Delaware limited liability company headquartered in San Diego, California, that is planning to offer electronic wallet services to consumers internationally and merchant payment capabilities in partnership with certain of its affiliated entities.
HUMBL is a cross-border payment processor that will offer an eWallet suite of payment solutions to consumers , as well as point of sale (“POS”) solutions to merchants, located across the world, and global cash pickup points at HUMBL “Hubs”. HUMBL will be generally involved in the business of sending and receiving funds globally. Services include, but are not limited to, e-wallet services, point of sale services, cash pickup points, and funds transfer services, mainly between the US and emerging countries (e.g., Costa Rica, Guatemala, Honduras). Consumers will be able to fund their e-wallet by connecting it to a bank account, credit or debit card, or other wallets (e.g., Google or PayPal), or incoming person-to-person transactions (‘the Remittance services”) from other e-wallet accountholders. Merchants will be able to instantly accept credit card payments utilizing a QR code.
As noted above, HUMBL plans to offer the remittance services in partnership with certain of its affiliated entities.
The other affiliates that HUMBL plans to partner with are: (i) its parent company, Block 30 Holding Co. LLC, Company Limited (“BLOCK 30 Holding Co.”), which, together with HUMBL LLC, is owned by Block 30 Holding Co. LLC., a company incorporated in Delaware, United States.
The above-referred remittance and payment services that HUMBL wishes to partner with these affiliates to offer are as follows, each of which is further described below:
• A cross-border remittance service which allows a consumer in the United States or any other country to transfer funds from their wallet to the wallet of another consumer in the same or different country; and
• A Wallet service which allows a consumer to pay for services using an app and a QR code, or to transfer funds to the wallet from a bank account or credit card.
2. Program Statement and Objectives
It is the policy of the Company to adhere to applicable federal and state laws. While it is the intention of the Company to meet the specific policy and procedure statements in this document, some of which are best practices, the Company expressly disclaims any enforceable legal obligation to do, perform or adhere to conduct, practice, or otherwise act beyond what is legally required. No person, entity, government or third-party may rely on these policy and procedure statements, any third-party benefit being expressly disclaimed.
This AML and CTF Program document (the “AML Program”) details the Company’s ongoing commitment to its AML and CTF obligations, as well as the critical control framework utilized by the Company to prevent, mitigate, and safeguard against financial crimes. This AML Program will be reviewed and approved by senior management.
The senior management team of HUMBL will demonstrate the Company’s commitment to compliance by:
• Setting a clear tone from the top of the organization about the importance of AML compliance, and by clearly communicating compliance responsibilities across all personnel;
• Demonstrating ongoing oversight of the AML Program through the following:
o Review of regular management information reports prepared by the CCO, as well as the results of the independent review of the AML Program;
o Allocation of appropriate human and technological resources to achieve and maintain compliance;
o Resolution of escalated issues;
o Periodic testing of internal controls to ensure accuracy and efficacy;
o As necessary, ensuring prompt corrective action to remediate systematic errors or control deficiencies; and
o Ensuring that AML training is provided to all employees annually.
The Company will also take reasonable steps to:
(1) Identify and detect suspicious activity;
(2) Accept as customers only applicants whose identities can be verified and reasonably established to be legitimate per HUMBL’s onboarding procedures;
(3) Prevent customers from using the Company to engage in money laundering, terrorism financing, and other criminal activity; and
(4) Maintain accurate and current information about each User as required.
The AML Program will be reviewed and updated on at least an annual basis to ensure policies, procedures, and internal controls are in place for both changes in regulations and changes to HUMBL or its business activities. As new markets, products and services, governing authorities, or jurisdictional requirements are introduced or developed, HUMBL will be proactive in enhancing the AML Program to meet or exceed regulatory expectations are reviewed annually and which complement the AML Program.
3. Regulatory Overview
3.1 Money Laundering, Terrorist Financing and Fraud
Money laundering is the process by which criminals, including terrorist organizations, attempt to disguise the proceeds, sources, or nature of their illicit activities. “Dirty” funds (proceeds from unlawful activities) that were obtained as the result of criminal activity are “laundered,” or made to appear legitimate, via their introduction to and passage through a legitimate business channel.
Generally, money laundering involves three stages: placement, layering, and integration.
• “Placement” is the introduction of unlawful proceeds into the financial system without attracting the attention of financial institutions or law enforcement;
• “Layering” is the disbursement of funds around the financial system to create confusion and complicate the paper trail that would lead to the source of funds; and
• “Integration” is the incorporation of illicit funds into the economy as seemingly legitimate business earnings.
These phases can occur chronologically or simultaneously. Money launderers may exploit a particular financial institution for use in all of those phases or use a financial institution for one aspect of a money laundering scheme.
Terrorist financing is the process of raising, moving, or using funds, by any means, with the intention or knowledge that they be used to support terrorist activity or fund terrorist organizations.
Fraud means wrongful or criminal deception intended to result in financial or personal gain. The Company is aware that fraud prevention is essential, particularly in e-commerce, because the risk associated with the customer not being present at the time of transaction. Hacking attempts, losses, and prevention are likely to increase with the rise in mobile banking applications, vulnerabilities of financial call centers, and increased sophistication of social engineering attacks.
3.2 Office of Foreign Asset Control
The U.S. Treasury's OFAC administers laws to impose economic and trade sanctions against entities and individuals, including targeted foreign countries, terrorists, international narcotics traffickers and those engaging in activities relating to the proliferation of weapons of mass destruction. These individuals and companies are called Specially Designated Nationals (SDNs) and Blocked Persons.
Economic and trade sanctions are economic and/or financial restrictions imposed by governments or international bodies on certain countries and specified individuals and entities for the purpose of addressing security threats.
3.3 The Bank Secrecy Act
The Financial Record keeping and Reporting of Currency and Foreign Transactions Act of 1970 (31 U.S.C. 5311, et seq.) is referred to as the Bank Secrecy Act. The BSA imposes a duty on financial institutions to identify and report potential money laundering activities, terrorist financing, illegal activities, and certain other suspicious transactions conducted by or through the business, and also to make and retain certain records regarding customers, transactions, and accounts.
Over time, a number of additional statutes and regulations have been enacted that expand and strengthen the scope of the federal government’s enforcement powers with regard to the BSA. Together, these statutes and regulations place a number of responsibilities on financial institutions, including MSBs, such as (i) identifying their customers and evaluating the risks of performing transactions for them; (ii) monitoring for suspicious, unusual, or unexpected activity, investigating such activity, and alerting FinCEN to such activity when appropriate; and (iii) screening transaction participants against various sanctions lists maintained by the U.S. government.
All financial institutions subject to the BSA, its implementing regulations, and related statutes are required to implement and closely adhere to written AML policies and procedures.
3.4 The Money Laundering Control Act
The U.S. federal criminal framework prohibiting the facilitation of money laundering is set out in the Money Laundering Control Act (“MLCA”). The MLCA provides for extraterritorial jurisdiction over the conduct of non-U.S. citizens if “the conduct occurs in part in the United States” or if the offense “takes place in the United States.”
In general, under the MLCA, it is a criminal offense to “knowingly” engage in certain “financial
transactions” or “monetary transactions” that involve the proceeds of “specified unlawful
activity.”
Violations of the MLCA require knowledge that property represents some form of criminal
activity and can be based upon specific criminal intent (under Section 1956) or, for transactions
over $10,000, the use of a financial institution (under Section 1957). Importantly, one cannot
argue that there was no knowledge due to a decision to forego AML screenings.
Willful blindness is the functional equivalent of knowledge and can serve as a basis for
prosecuting a crime requiring that the defendant possessed knowledge of a particular fact.
3.5 The Five Pillars
In order to be considered effective, an AML compliance program must contain the following required elements, commonly referred to as the “five pillars” of AML compliance:
• A senior compliance officer (or Chief Compliance Officer) having sufficient knowledge, authority, and resources to oversee the company’s AML program.
• A risk-based written compliance program reasonably designed to prevent the business from being used to facilitate criminal activity;
• An AML training program for employees that includes both training for new personnel and annual training for all employees;
• A periodic independent review of the company’s performance in carrying out its AML compliance obligations; and
• Customer due diligence, including customer identification and verification, beneficial ownership identification and verification, and understanding the purpose and nature of customer relationships to develop a customer risk profile.
Details regarding HUMBL’s implementation of each of the above requirements are included in the following sections.
4. Compliance Officer
Senior management is responsible for appointing the AML Compliance Officer, who will generally be the same individual appointed to the role of CCO (and, accordingly, referred to within the organization as such). As appointed by senior management, the CCO shall:
• Have the necessary authority to implement, enforce and maintain this AML Program;
• Monitor changes to government regulations and industry best practices so that the AML Program and any related procedure documents can be updated accordingly;
• Remain independent of the Company’s other teams and have the authority to cross departmental lines to perform compliance reviews and implement corrective actions;
• Ensure that HUMBL creates, maintains, and files reports in a manner consistent with the requirements imposed by this AML Program, along with those imposed by OFAC and by the BSA and the PATRIOT Act (together with their respective implementing regulations);
• Conduct a risk assessment of the Company’s entire business on an annual basis (or more frequently to meet business needs such as product launches or client acquisition);
• Implement an AML training program for all relevant employees;
• Serve as the principal point of contact for any regulatory examinations and for compliance or licensing matters between HUMBL and (i) FinCEN, OFAC, or other subdivisions of the U.S. Department of the Treasury; (ii) the Federal Bureau of Investigation (“FBI”); or (iii) state regulatory agencies;
• Provide quarterly updates to the Board on the AML Program and related issues;
• Ensure that the Company keeps and maintains all of the required AML records and ensure that any information regarding suspicious activity will be maintained for potential suspicious activity report (“SAR”) filing;
• Consult with internal or external legal counsel on matters wherein the CCO deems that legal guidance would benefit AML Program implementation; and
• Have full access to company financial information, transaction data and customer data whenever necessary to fulfill his or her designated responsibilities.
Additional information regarding the specific roles and responsibilities of the officers, directors, and senior management of HUMBL with respect to this AML Program is set forth below in Section 13.
5. Internal Risk Assessment
The Company will conduct periodic Risk Assessments designed to evaluate the extent of the AML risk arising from the Company’s activities. The risk assessment defines inherent risk factors, identifies risk mitigation efforts, and assigns a residual risk rating to each category of risk. This process is conducted for all HUMBL products, customers, and jurisdictions. The risk assessment is to be performed at least annually and should be updated whenever the Company makes any material changes to its activities or operations.
The periodic risk assessment forms the foundation from which the AML Program is designed and revised year-over-year. Accordingly, on at least an annual basis, the CCO will perform the risk assessment and present the findings to the Board, in addition to making any necessary alterations to this AML Program.
More specifically, the CCO will use the results of each risk assessment to:
• Understand the Company’s AML, CTF and Sanctions risk profile;
• Determine the adequacy and effectiveness of the Company’s AML, CTF and Sanctions controls;
• Evaluate the adequacy and application of the Company’s AML, CTF and Sanctions resources;
• Identify the existence of any unmitigated and/or unacceptable AML, CTF and Sanctions risk; and
• If necessary, recommend and implement modifications to the Company’s activities and/or the AML Program (or the accompanying procedures and processes) to bring the AML, CTF and Sanctions risk to an acceptable level.
6. Sharing AML Information with Federal Law Enforcement Agencies and Other Financial Institutions
1. FinCEN Requests (only applicable to MSBs)
If the Company receives a FinCEN request concerning accounts and transactions (“314(a) Request”) in regard to a User, the Company will review and respond to the 314(a) Request and will endeavor to conduct a review of the activity to determine if any activity in the account is suspicious. No employee may issue a response to a 314(a) Request without the approval of the Chief Compliance Officer and Company Counsel. All 314(a) Requests and responses to 314(a) Requests will be kept strictly confidential and stored in either a locked cabinet in the office of the General Counsel or Chief Compliance Officer, or electronically in a database with access strictly limited by the General Counsel and Chief Compliance Officer.
a. Procedures
Under Treasury’s final regulations (published in the Federal Register on September 26, 2002), the Company will respond to a Financial Crimes Enforcement Network (“FinCEN”) request about accounts or transactions by promptly searching our records, at our head office in the United States, to determine whether we maintain or have maintained any account for, or have engaged in any transaction with, each individual, entity, or organization named in FinCEN's request. Upon receiving an information request, the Company will designate one person to be the point of contact regarding the request and to receive similar requests in the future. Unless otherwise stated in FinCEN's request, the Company is required to search current accounts, accounts maintained by a named suspect during the preceding 12 months, and transactions conducted by or on behalf of or with a named subject during the preceding six months.
If the Company finds a match, the Company will report it to FinCEN by completing FinCEN’s subject information form. This form can be accessed at https://www.fincen.gov/314a/#/ or sent to FinCEN by electronic mail at sys314a@fincen.gov or another acceptable method. If the search parameters differ from those mentioned above (for example, if FinCEN requests longer periods of time or limits the search to a geographic location), the Company will limit its search accordingly.
If the Company searches its records and does not uncover a matching account or transaction, then it will not reply to a 314(a) request.
The Company will not disclose the fact that FinCEN has requested or obtained information from the Company, except to the extent necessary to comply with the information request. The Company will maintain procedures to protect the security and confidentiality of requests from FinCEN, such as those established to satisfy the requirements of Section 501 of the Gramm-Leach-Bliley Act.
The Company will direct any questions we have about the request to the requesting Federal law enforcement agency as designated in the 314(a) Request.
Unless otherwise stated in the information request, the Company will not be required to treat the information request as continuing in nature, and the Company will not be required to treat the request as a list for purposes of the customer identification and verification requirements. The Company will not use information provided to FinCEN for any purpose other than (1) to report to FinCEN as required under Section 314 of the USA PATRIOT Act; (2) to determine whether to establish or maintain an account, or to engage in a transaction; or (3) to assist the Firm in complying with any requirement of Section 314 of the USA PATRIOT Act.
2. National Security Letters
National Security Letters (“NSL(s)”) are written investigative demands issued by the Federal Bureau of Investigation (“FBI”) or other federal government authorities to obtain financial records from financial institutions. NSLs are issued for purposes of counterintelligence and counterterrorism investigations. No financial institution or officer, employee or agent of the institution can disclose to any person that a government authority or the FBI has sought or obtained access to records through an NSL.
The Company will maintain the highly confidential nature of NSLs. An NSL issued to the Company will be handled by the Company Counsel and the Chief Compliance Officer. If any employee receives a copy of the NSL, the recipient must promptly notify the Chief Compliance Officer and Company Counsel. To maintain the confidentiality of the records request, the Company Counsel and Chief Compliance Officer of the Company will work with select employees and limit the disclosure of the source of the request. The Company Counsel and Chief Compliance Officer will maintain the only copy of the NSL and copies of all documents provided to the issuer of the NSL. All NSL files will be kept in either a locked cabinet in the office of the Company Counsel and Chief Compliance Officer, or electronically in a database with access strictly limited by the Company Counsel and Chief Compliance Officer.
The Chief Compliance Officer understands that receipt of an NSL does not, by itself, require the filing of a SAR. The Chief Compliance Officer, or designee, will conduct an investigation and assess the information to determine whether a SAR must be filed.
Any questions that the Company may have regarding NSLs will be directed to the local FBI field office. Contact information for the FBI field offices can be obtained from the FBI's website at www. FBI.gov.
3. Grand Jury Subpoenas
When the Company receives a grand jury subpoena, the Company will conduct a risk assessment of the customer subject to the subpoena as well as review the customer’s account activity. If suspicious activity is uncovered during the Risk Assessment and review, the Company will evaluate whether a SAR is required, and whether the customer’s account should be restricted or terminated. The Company understands that none of its officers, employees or agents may directly or indirectly disclose to the person who is the subject of the subpoena its existence, its contents or the information the Company used to respond to it.
To maintain the confidentiality of any grand jury subpoena the Company receives, the Company will process and maintain the subpoena as follows:
• Grand jury subpoenas are received by the Company in all locations of the Company and its registered agents. The recipient will forward the subpoena to the Company Counsel. In cases where no records are located, the Company Counsel or a designee will handle and respond accordingly. The Company will work with the Company Counsel to respond to the subpoena.
• When the Company receives a grand jury subpoena served on the Company that is or could potentially be related to AML or OFAC compliance, the Company Counsel handling the matter will provide a copy of the subpoena to the Chief Compliance Officer.
• The Chief Compliance Officer will identify all User accounts that may be associated with the grand jury subpoenas received by the Company, and each such account will be reviewed for suspicious activity. SARs and other reports will be made by the Chief Compliance Officer as required, based on the results of this review. The Chief Compliance Officer, with the assistance of staff or a third-party service provider, will endeavor to conduct a search of the Company electronic databases or distributed platform to determine if the subjects of the subpoena hold additional accounts or have been parties to transactions.
4. Voluntary Information Sharing with Other Financial Institutions Under USA PATRIOT ACT Section 314(b) (only applicable to MSBs)
Subject to the applicable USA PATRIOT Act and implementing regulations (“Rules”) and guidance from the legal counsel as needed, the Company will share information about those suspected of terrorist financing and money laundering with other financial institutions for the purposes of identifying and reporting activities that may involve terrorist acts or money laundering activities and to determine whether to establish or maintain an account or engage in a transaction. In accordance with the Rules, if elected, the Company will file with FinCEN an initial notice before any sharing occurs and annual notices afterwards. The Company will use the notice form found at www.fincen.gov. Before the Company shares information with another financial institution, it will take reasonable steps to verify that the other financial institution has submitted the requisite notice to FinCEN, either by obtaining confirmation from the financial institution or by consulting a list of such financial institutions that FinCEN will make available.
This requirement applies with respect to financial institutions with whom we are affiliated, and so the Company will obtain the requisite notices from affiliates as needed and follow required procedures when appropriate.
The Company will employ reasonable procedures both to ensure that relevant information is shared and to protect the security and confidentiality of this information, including segregating it from the Company’s other books and records as appropriate.
The Company also will employ reasonable procedures to help ensure that confidential information received from another financial institution shall not be used for any purpose other than as intended:
• identifying and, where appropriate, reporting on money laundering or terrorist activities;
• determining whether to establish or maintain an account, or to engage in a transaction; or assisting the financial institution in complying with performing such activities.
7. Know Your Customer (“KYC”)/Customer Identification Program (“CIP”)
The Company has established, documented and maintains a Know Your Customer (“KYC”) / Customer Identification Program (“CIP”). The Company will collect certain minimum identification information from each customer; utilize risk-based measures to verify the identity of each customer; record customer identification information and the verification methods and results; and provide the required CIP notice to customers for which Company seeks identification information to verify their identities.. Each customer of HUMBL will be screened at onboarding and periodically thereafter for as long as they remain a customer.
7.1 Customer Identification Program/Customer Due Diligence
Customer Identification Program (“CIP”) refers to the risk-based verification program HUMBL will apply to each of its customers at the time a customer relationship is initiated (“onboarding”). Customer Due Diligence (“CDD”) refers to the process the Company will use to collect and evaluate relevant information about its customers throughout the entire relationship to determine the risk the customers pose for financial crimes.
At the time of onboarding, each customer of HUMBL is evaluated and assigned a level of risk. This initial assessment will consider the following information to determine a customer’s risk level: (i) customer demographics and personal identifiable information (e.g., a customer’s occupation, place of residence or work, contact information, date of birth, SSN/TIN and ID type); (ii) business type, if an entity, and beneficial ownership information for the entity; and (iii) region (state or province and city). After consideration of these elements, each customer will be assigned an initial risk rating of either low, high, or very high risk. As discussed further below, the information required for this initial assessment is obtained from each customer when a relationship with the customer is initiated, and the type and scope of the information collected depends on which of the Company’s services the customer intends to use.
Senders wishing to use the cross-border payments to send payments to friends or relatives are required to provide the following information prior to being permitted to utilize the service:
• Full legal name;
• Bank account details or debit card account information;
• Residential address;
• Date of Birth;
• Nationality;
• Email address; and
• Telephone number.
Senders who wish to send an amount greater than $1,000 are required to first provide the following additional information to HUMBL:
• Occupation;
• Date of birth;
• A clear, color photocopy of their unexpired government issued identification card or passport; and
• A document (i.e., a bank statement, utility bill, or other document) to verify the Sender’s residential address.
A Sender’s identity and address are verified by a third-party verification system. The Sender will also be screened against various watchlists. Finally, open source material (e.g., LexisNexis, Yahoo, and Google) may be used to validate and confirm the information provided by the Sender, as well as to run adverse media and negative news screens.
In addition to the above information, before any transaction can be initiated, a Sender must provide the following information regarding the designated Recipient:
• Full legal name;
• Residential address;
• Date of birth;
• The name of the receiving bank and account number; and
• Identification number (i.e. SSN, TIN, Driver’s License)
At the time of opening an account for a legal entity customer, the Company will identify any individual that is a beneficial owner of the legal entity customer by identifying any individuals who directly or indirectly own 25% or more of the equity interests of the legal entity customer, and any individual with significant responsibility to control, manage, or direct a legal entity customer. The following information will be collected for each beneficial owner:
• (1) the name;
• (2) date of birth (for an individual);
• (3) an address, which will be a residential or business street address (for an individual), or an Army Post Office (APO) or Fleet Post Office (FPO) box number, or residential or business street address of next of kin or another contact individual (for an individual who does not have a residential or business street address); and
• (4) an identification number, which will be a Social Security number (for U.S. persons), or one or more of the following: a passport number and country of issuance, or other similar identification number, such as an alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or other similar safeguard (for non-U.S. persons).
All senders and receivers, individuals and entities, will be subject to adverse media, negative news, and PEP status screenings, either via third party vendor or internally using open source material. Any negative news will be taken into account during onboarding and periodic customer reviews, and risk-ranked to determine the likelihood that the customer is, or may become, involved in illicit activity.
For verification, the Company will describe any document relied on (noting the type, any identification number, place of issuance and, if any, date of issuance and expiration). The Company will also describe any non-documentary methods and the results of any measures undertaken.
If a customer either refuses to provide the information identified above when requested, or appears to have provided inaccurate or misleading information, or gives the Company reason to believe they are in any way involved with fraud, money laundering, or any other criminal activity, the Company may not permit such customer to create an account and, after considering the risks involved, consider closing any existing account. In either case, the Chief Compliance Officer must be notified so that they, on behalf of the Company, can review the account and take appropriate action. When the Company cannot form a reasonable understanding of the true identity of a prospective customer, the Company may do the following: (A) not open an account; (B) impose terms under which a customer may attempt to conduct transactions while we verify the customer’s identity; (C) close an account, if already opened, after attempts to verify customer’s identity have failed; and/or (D) file a SAR in accordance with applicable law and regulation.
7.2 Enhanced Due Diligence
In certain circumstances, the Company may identify a customer as “high risk” or “very high risk” using the assessment method described above. For these customers, Enhanced Due Diligence (“EDD”) is conducted by collecting and evaluating the information listed below in addition to the information listed above that is collected from every customer.
For Senders or Recipients that are identified as “high risk” or “very high risk”, the Company may collect:
• Information concerning their source of wealth and/or income (i.e., bank statement, pay stubs, investment account statement, tax returns);
• Information concerning the usage of services and expected activity; and
• Information regarding the relationship between the Sender and Recipient and/or purpose of the transaction.
An additional media search may be conducted for any individual or entity characterized as “high risk” or “very high risk.” In addition to collecting the above information, a Company representative may contact the Sender by phone, if appropriate. During the ensuing telephone discussion, the following red flags may indicate that a higher risk rating is warranted:
• Customer has an unusual or excessively nervous demeanor;
• Customer discusses the company’s compliance requirements or requests with the apparent intention of not complying with them;
• Customer threatens the Company’s employee in an effort to discourage required recordkeeping and reporting;
• Customer suggests paying a gratuity or providing some other benefit or incentive to the Company’s employee or a related third party; or
• Customer appears to have a hidden agenda or behaves abnormally (e.g., does not care about the fees).
The customer will ultimately be approved or rejected by HUMBL based upon its observations and evaluation of the information collected.
7.3 Politically Exposed Persons
Additional risks arise when financial institutions have accounts for or conduct transactions on behalf of a senior foreign political figure, often referred to as a “politically exposed person” (“PEP”). Financial institutions are charged with ensuring that they do not knowingly or unknowingly assist in hiding or moving the proceeds of corruption by PEPs.
More specifically, the term “PEP” includes current or former senior foreign political figures, their immediate families, and their close associates. The term “senior foreign political figure” means a current or former senior official in the executive, legislative, administrative, military or judicial branches of a foreign government (whether elected or not), a senior official of a major foreign political party, or a senior executive of a state-owned entity. HUMBL will review public information, including information available in commercial databases, as well as utilize third-party vendor software to verify PEP status (information concerning PEP status will be collected during onboarding and during any part of the CDD process.)
In addition to its normal CDD procedures, HUMBL will subject any potential PEP to EDD (as each is described above) in order to understand the nature and current political status of the PEP and how he or she intends to use the Company’s services. The results of the Company’s CIP and CDD, as applied to the potential PEP, will be evaluated by the CCO to determine if the Company will conduct business with the PEP. If approved, the PEP will be monitored on an ongoing basis consistent with the Company’s risk-based approach to its CIP. Documentation of the CCO’s decision to approve or decline the PEP, as well as all CIP documentation, will be retained according to this policy.
7.4 Prohibited Customers
Certain customers inherently pose higher ML/TF risks than HUMBL is willing to accept. HUMBL will not enter into client relationship with the following persons, and will immediately terminate the relationship and close all accounts with anyone found to belong to one of the following categories of prohibited customers:
• Sanctioned or embargoed parties on the sanction lists issued by
United Nations (UN Sanctions), European Union (EU Sanctions), the
Office of Foreign Assets Control of the United States (US OFAC
Sanctions), the Office of Financial Sanctions Implementation (UK
OFSI Sanctions) or equivalent or similar sanction lists;
• Residents in countries or Jurisdictions identified by the Financial
Action Task Force (FATF) as a high-risk jurisdiction with strategic
AML/CFT deficiencies;
• Persons using fictitious names or engaging in illegal business
(unauthorized business or narcotics and marijuana);
• Entities designated under Section 311 of the USA PATRIOT ACT by the US Department of Treasury;
• Unregulated or unlicensed remittance agents, exchange houses, casas de cambio, or money transfer agents;
• Unlicensed banks or unlicensed NBFI (Non-Bank Financial Institution); and
• Shell banks or entities that provide services to shell banks.
7.5 Periodic and Event-Driven Reviews
Event-driven reviews enable HUMBL to have ongoing visibility into existing customers’ patterns of activity, which ensure the customer’s risk profile is kept up-to-date and accurate. The frequency of the event-driven review is determined by the customer type, volume of activity, or a triggering event. Such a review may result in increased monitoring of the customer or, in certain cases, the suspension or termination of the customer relationship. Examples of scenarios that may trigger an event-driven review might include:
• A change in the customer’s controlling party or beneficial ownership information;
• Inconsistencies in or a change to the customer’s information previously provided;
• Customer behavior and transaction activity that appears unusual or potentially suspicious upon review;
• Negative news, litigation, and/or regulatory actions against the customer;
• Any event involving a customer which could cause reputational risk to the Company;
• Profile or payment account reactivation; and
• Any other event or situation deemed as questionable or otherwise warranting further review by HUMBL.
In addition to event-driven reviews, HUMBL performs periodic recurring reviews on all customers at intervals determined based on the customer’s current risk rating. Customers that are determined to be very high or high-risk will be subject to reviews every 6-12 months and low-risk customers will be subject to reviews every 24-36 months. The results of the periodic and event-driven reviews are used to re-evaluate customers’ risk ratings, which may be adjusted from time to time based on such reviews.
Additional information regarding the Company’s Customer Identification Program is available in the Company’s AML and Internal Control Procedures.
7.6 Recordkeeping
The Company will document its verification, including all identifying information provided by a customer, the methods used and results of verification, and the resolution of any discrepancies identified in the verification process. If the Company or its designated third-party service provider requests and documents as part of verifying a customer’s identity, the Company will keep records containing a description of any document that the Company relied on to verify the customer’s identity, noting the type of document, any identification number contained in the document, the place of issuance, and the date of issuance and expiration date (if any). The Company will retain documents that describe the methods and the results of any measures the Company took to verify the identity of a customer. The Company will also keep records containing a description of the resolution of each substantive discrepancy discovered when verifying the identifying information obtained. The Company will retain records of (i) all customer identification information, and (ii) verification process for the customer’s identity for five years after an account has been closed.
7.7 Notice to Customers
Federal law requires that persons be notified that the Company is collecting information about them that will be used to verify their identities. Prior to permitting the customer to open an account, the Company will notify the customer that the Company will be collecting and maintaining information about them that will be used to verify their identity.
8. Monitoring and Reporting Suspicious Activity
8.1 Monitoring Suspicious Activity
HUMBL, together with each employee of the Company, has a duty to report any actual or suspected financial crime. To that end, HUMBL will implement controls and procedures designed to assist employees in identifying suspicious activity by Senders and Recipients who use the services described herein.
HUMBL will implement strict controls such as real-time monitoring to verify customers for legitimacy by confirming data that such entities and individuals provide pursuant to the Company’s CIP. In addition, HUMBL will place procedures and systems in place, as described above, to assist its employees in monitoring transactional activity on an ongoing basis. Among other controls, all of which are described in further detail in the Company’s AML and Internal Control Procedures, HUMBL will impose transaction limits, both in terms of dollar amount and in frequency of transactions, to further mitigate the risk of its cross-border payments attracting the attention of persons who might wish to use them for criminal purposes. In short, HUMBL will utilize a combination of manual and automated processes to detect money laundering and terrorist financing activities, as well as potential fraud and other crimes.
Listed below are some examples of red flags that would prompt a Company employee to investigate the transaction or transactions further to determine whether an escalation and/or a report is warranted:
• A Sender originates an unusually high number of transfers to multiple Recipients;
• A Recipient receives an unusually high number of transfers from one or more Senders;
• A Sender transfers a pattern of high dollar amounts to a Recipient;
• A Sender appears to structure transfer payments into smaller dollar amounts to avoid reporting of the same under federal identification requirements (as detailed below) or the Company’s internal policy;
• Groups of Senders conduct transactions that are not consistent with prevailing money transfer trends among expatriates, travelers, or migrant workers sending funds to friends and family; and
• Any activity that appears to have no apparent legitimate or lawful purpose.
8.2 Reporting Suspicious Activity
A Suspicious Activity Report (“SAR”) will be filed with FinCEN if a transaction is conducted or attempted by, at, or through HUMBL that involves or aggregates funds of at least $2,000 where HUMBL knows or suspects that the transaction (or pattern of transactions):
• Involves funds derived from illegal activity, or is intended to disguise funds or assets derived from unlawful activity, as part of a plan to violate or evade any federal law or regulation, or to avoid any transaction reporting requirement under federal law or regulation;
• Is designed, whether by structuring or other means, to evade any requirements of AML regulations;
• Serves no business or apparent lawful purpose, and the Company knows of no reasonable explanation for the transaction after examining the available facts, including the background and possible purpose of the transaction; or
• Involves the use of the Company to facilitate criminal activity (in some cases, regardless of the aggregate funds moved by, at or through the company).
The CCO will follow procedures documented in the Company’s AML and Internal Control Procedures, to ensure that a SAR is filed with FinCEN within thirty (30) calendar days of the initial detection and confirmation of facts that may constitute the basis for a SAR filing. All information related to the SAR or potential SAR will be tracked in a “SAR Log” maintained by the CCO or a designee. If a SAR is not ultimately filed, the circumstances surrounding the initial suspicion and the decision not to file a SAR will be documented, including both the date and the nature of the decision, and the reviewer’s name.
In situations involving violations that require immediate attention, such as discovery of terrorist financing or ongoing money laundering schemes, the Chief Compliance Officer, on behalf of the Company, will endeavor to call as soon as possible an appropriate law enforcement authority. If a customer appears on the OFAC Lists, the Chief Compliance Officer will call the OFAC Hotline at (800) 540-6322. Other contact numbers the Chief Compliance Officer may use are: FinCEN's Financial Institutions Hotline ((866) 556-3974) (especially to report transactions relating to terrorist activity), local U.S. Attorney's office, local FBI office and local SEC office (to voluntarily report such violations to the SEC in addition to contacting the appropriate law enforcement authority). If the Chief Compliance Officer notifies the appropriate law enforcement authority of any such activity, the Chief Compliance Officer and the Company will still review the suspicious activity for the potential filing of a timely SAR.
The Company’s policy is that no employee shall discuss the potential existence of, or any content that may or may not be disclosed in, a SAR. Any questions related to a SAR should be referred to the CCO, who will respond appropriately as permitted by applicable law. The CCO will update the Board on a quarterly basis regarding the number of SARs filed and the reasons for filing without divulging any information about the individuals involved in or the details of any particular SAR. HUMBL will monitor the activities of any individual involved in activity that results in a SAR for repeated behavior and will report on recurring activity as appropriate through FinCEN’s BSA e-filing system. The Chief Compliance Officer will retain copies of any SAR filed and the original or business record equivalent of any supporting documentation for five (5) years from the date of filing the SAR. The Chief Compliance Officer will identify and maintain supporting documentation and make such information available to FinCEN, any other appropriate law enforcement agencies, or federal or state securities regulators, upon request.
The Chief Compliance Officer will not notify any person involved in the transaction that the transaction has been reported, except as permitted by the BSA regulations.
9. Regulatory Reporting and Recordkeeping
9.1 Currency Transaction Reporting
HUMBL will comply with the requirements of FinCEN’s Currency Transaction Reports (“CTR”) to the extent they are applicable. HUMBL will file a CTR for any deposit, withdrawal, exchange of currency, or other payment which involves a transaction of more than $10,000 within the United States, or group of transactions for a single individual that occur in one day which also meet reporting requirements.. In addition, HUMBL shall maintain internal records of all global cash or currency transactions greater than $10,000, regardless of whether a CTR is required or not.
9.2 Purchase and Sale of Monetary Instruments Recordkeeping
HUMBL has no plans to purchase or sell monetary instruments. If, in the future, HUMBL develops plans to purchase or sell monetary instruments, the CCO will amend this AML Program and ensure that the Company develops appropriate procedures in advance of commencing such activity.
9.3 Reports of International Transportation of Currency or Monetary Instruments (“CMIRs”)
The CMIRs requirements do not currently apply to HUMBL because it does not transport, mail, or ship currencies or monetary instruments as those terms are defined by the IRS and the U.S. Department of the Treasury. If, due to a change in such definitions or the Company’s business activities, HUMBL begins accepting currency or monetary instruments, the CCO will amend this AML Program and develop procedures for filing CMIRs in accordance with the relevant regulations.
9.4 Foreign Bank and Financial Accounts Reporting (“FBARs”)
The CCO may ensure that HUMBL files timely FBARs for all foreign bank and financial accounts held by the Company that exceed $10,000 at any time over the previous calendar year. HUMBL may complete a FBAR in relation to its own accounts as well as any relevant customer accounts in which it has a financial interest or over which it has signature authority, and will retain records of the accounts for which a form was filed.
9.5 Blocked Transactions
The CCO shall file an annual report of all transactions that have been blocked as a result of the Company’s OFAC screening regime for the year ending June 30. This annual report is due by September 30 of each year and should be completed on the Annual Report of Blocked Property form. The completed form may be mailed to the HUMBL bank partner.
9.6 Agents
HUMBL will maintain a list of its Agents and their corresponding owners, as well as appropriate risk-based agent monitoring policies and procedures. Each agent will maintain an effective AML program, to be approved and overseen by the Company. Part of Agent monitoring will be to evaluate operations on an ongoing basis, as well as to monitor for variations in those operations, as well as to evaluate the Agent’s implementation of mandated policies and procedures.
Prior to entering into any relationship with a new Agent, the Company will conduct all necessary due diligence on the Agent and the Agent’s owners and employees. Information the Company will collect and conduct a risk assessment on includes:
• Location/jurisdiction of the Agent, including the extent to which the relevant jurisdiction is internationally recognized as presenting a greater risk for money laundering, or is considered to have more robust AML standards;
• Ownership of the Agent;
• The extent to which the Agent, if located outside the US, is subject to AML requirements in its jurisdiction;
• The markets the Agent serves, and the extent to which its markets present increased exposure to money laundering/terrorist financing; and
• Types and purposes of services to be provided, as well as anticipated activity with the Agent.
The Company will periodically reassess risks associated with Agents, including but not limited to business services, clients, size, location, and circumstances. The Company maintains responsibility for addressing any weaknesses or deficiencies in an Agent’s AML program. The Company will provide AML training on at least a yearly basis, and may employ the services of a third-party expert to conduct an independent review of Agent AML programs.
If at any point an Agent fails to appropriately implement or maintain any aspect of the risk-based AML program, or is otherwise non-compliant with Company and/or state or federal regulations or procedures, the Company will terminate the Agent’s contract.
The CCO will develop any further policies and procedures for due diligence, monitoring, and oversight of the Company’s Agents.
9.7 Funds Transmittal Recordkeeping: “The Travel Rule”
The “Travel Rule” requires that any company subject to the rule collect and maintain records of all funds transfers valued at $3,000 or more in aggregate on the same day. The following information will be included for each applicable transaction record and will also be transmitted to the receiving financial institution:
• Name of the transmitter and, if the payment is ordered from an account, the account number;
• Either the name and address or the numerical identifier of the transmitter’s financial institution;
• Address of the transmitter;
• Amount of the transmittal order;
• Date of the transmittal order;
• Identity of the recipient’s financial institutions; and
• As many of the following items as possible:
o Name and address of recipient;
o Account number of the recipient; and
o Any other specific identifier of the recipient.
HUMBL will comply with the requirements of the Travel Rule to the extent that they are applicable to any transaction.
9.8 AML Recordkeeping
The Chief Compliance Officer and his or her designee will be responsible for ensuring that AML records are maintained properly. The Company AML related records will be maintained for a period of five (5) years. This includes but is not limited to AML related inquiries, CTRs, forms filed, and sharing of information (as applicable). It also includes OFAC searches and related section 314a and 314b USA PATRIOT Act records that will be maintained in the customer account files and/or a binder or in the Company’s Legal drive or other appropriate location, credit searches if applicable, and related CIP information that will be incorporated into the customer account files. The annual independent testing of AML reports and all such related supporting documentation, as well as training certifications, will be maintained in the AML compliance files.
9.9 Additional Records
The Company will retain either the original or other copy or reproduction of each of the following; if applicable:
• A record of each advice, request or instruction received or given regarding any transaction resulting (or intended to result and later canceled if such a record is normally made) in the transfer of currency or other monetary instruments, funds, checks, investment securities or credit, of more than an equivalent value of $10,000 to or from any person, account or place outside the U.S.;
• A record of each advice, request or instruction given to another financial institution (which includes broker-dealers) or other person located within or without the U.S., regarding a transaction intended to result in the transfer of funds, or of currency, other monetary instruments, checks, investment securities or credit, of more than an equivalent value $10,000 to a person, account or place outside the U.S.;
• Each document granting signature or trading authority over each customer’s account;
• A record of each remittance or transfer of funds, or of currency, checks, other monetary instruments, investment securities or credit, of more than an equivalent $10,000 to a person, account or place, outside the U.S.; and
• A record of each receipt of currency, other monetary instruments, checks or investment securities and of each transfer of funds or credit, of more than an equivalent $10,000 received on any one occasion directly and not through a domestic financial institution, from any person, account or place outside the U.S.
10. AML Compliance Training Program
The CCO will be responsible for developing, or overseeing the development of, the Company’s risk-based AML, CTF and Sanctions Compliance Training Program (the “Training Program”). The Training Program is designed to educate directors, officers and employees of HUMBL about the AML Program and their role in detecting and preventing money laundering and terrorist financing. To that end, HUMBL requires all directors, officers and employees to receive annual AML training that is appropriate to their roles and responsibilities. This training covers the Company’s regulatory obligations, awareness of money laundering and terrorist financing, and the detection of unusual activity, as well as the procedures to follow if money laundering or unusual activity is observed or suspected.
The Training Program will be offered to all HUMBL personnel at the time of hire and thereafter on an annual basis. Additional training is mandated for employees whose jobs impact the Company’s AML, CTF and Sanctions compliance efforts.
The training will include, at a minimum: (1) how to identify red flags and signs of money laundering that arise during the course of the employees’ duties (“Red Flags”); (2) what to do once the risk is identified (including how, when and to whom to escalate unusual activity or other Red Flags for analysis); (3) what employees’ roles are in the Company's compliance efforts and how to perform them; (4) the Company’s record retention policy; and (5) the disciplinary consequences (including civil and criminal penalties) for non-compliance with the BSA.
The Company may utilize a third-party service provider to deliver this training to employees. The Company will maintain records to show the persons trained, the dates of training and the subject matter of their training.
11. Independent Review of the AML Program
On an annual basis, the CCO will arrange for the independent review of the AML Program by a qualified third-party individual or firm (the “Auditor”). The review assesses the implementation and effectiveness of the AML Program and the adequacy of its controls over AML risk.
The independent review will include interviewing relevant compliance, operations and financial representatives of the Company involved in the program; reviewing the Firm’s AML program compliance and operational procedures as needed; independently identifying and reviewing select customer transactions during the review period; and reviewing the books and records of the Company by inspecting select documentation as required. Included in such a review are verifications of:
• FinCEN Requests under USA Patriot Act Section 314(a);
• USA Patriot Act Section 314(b)-Notice for Voluntary Sharing;
• Checking the Office of Foreign Assets Control (“OFAC”) Listing;
• A sample review of the Customer Identification Program (“CIP”);
• Correspondent Accounts for Foreign Correspondents and Shell Banks (when and if applicable);
• Monitoring Accounts for Suspicious Activity;
• Suspicious Transactions and Currency Reporting;
• Training; and
• AML Recordkeeping
Following each independent review, the management of HUMBL will prepare a response to any findings and recommendations cited by the Auditor. The CCO will share the Auditor’s report and the management response with the Board at the meeting following the completion of the independent review. Additionally, the CCO will track the Company’s compliance with the Auditor’s recommendations and any subsequent recommendations by the Board. Additionally, the Chief Compliance Officer may arrange for an internal team to perform testing or an independent review. To ensure independence when needed, the Chief Compliance Officer will be empowered to report the results of the independent review directly to the Board of Directors.
12. Monitoring Active Employee Conduct and Accounts
The Company will subject personal employee accounts on HUMBL (if any) to the same AML procedures as customer accounts, under the supervision of the Chief Compliance Officer. The Chief Compliance Officer's accounts (if any) will be reviewed by the Company Counsel or a third-party consultant or outside legal counsel that the Company Counsel may designate. The Board of Directors of the Company may also order review of employee conduct and accounts, as it deems appropriate to fulfill the objectives of this Policy.
13. Roles and Responsibilities
This section describes the roles and responsibilities of relevant parties in managing and executing the AML Program.
13.1 Senior Management
Senior Management is responsible for:
• Setting an appropriate tone from the top that positively establishes a culture of AML compliance to ensure employee awareness and adherence;
• Reviewing and approving the AML Program, AML Risk Assessment, and other Company policies;
• Understanding how the risk assessment and supporting AML Program serve to mitigate the risks to the Company that are related to money laundering, terrorist financing, fraud, and sanctions;
• Providing the necessary human and technological resources to ensure the day-to-day compliance obligations are met;
• Overseeing the AML Program to ensure the Company maintains an effective financial crime control framework, where policies, procedures and processes are designed to limit the risk of a financial crime being committed; and
• Appointing the CCO and ensuring that the CCO is provided with the proper authority and resources to carry out the CCO’s responsibilities.
13.2 The Chief Compliance Officer
The CCO will be responsible for:
• Ensuring the Company’s registration with FinCEN remains current and is renewed in a timely manner;
• Establishing relations with state regulators and supporting the maintenance of the money transmitter licenses, including all reporting, renewals, inquiries and examinations related to the licenses;
• Owning this policy and the risk assessment process to include periodic review, approval by the Board, and changes to the AML Program as necessary and appropriate for the business;
• Overseeing the administration of and the day-to-day compliance with the AML Program while acting as a liaison to senior management and the business units within HUMBL;
• Providing senior management with updates with respect to the effectiveness of the AML Program, exam results, appropriate training, legislative updates, SARs filed, and other topics;
• Serving as a Subject Matter Expert to support internal business units in complying with this AML Program;
• Providing employees with a level of training commensurate with their job responsibilities and sharing compliance information across the organization to promote a strong culture of compliance;
• Establishing procedures to track the completion of the AML, CTF and Sanctions training provided to Company personnel;
• Acting as a primary point of contact for regulatory matters, law enforcement requests, and information sharing with respect to outside parties;
• Designing and enforcing controls to ensure all federal recordkeeping and reporting required of MSBs is completed in an accurate and timely manner;
• Facilitating an independent review of the AML Program on a recurring basis and managing any action plans resulting from the review; and
• Creating and implementing internal testing programs to ensure the AML internal controls are working as intended.
13.3 The Business Units and Employees
Senior management and all employees of the Company are responsible for:
• Understanding their roles and responsibilities under this AML Program and maintaining awareness of financial crime risks;
• Ensuring each business unit’s policies, procedures and processes are designed to fully comply with the requirements of this policy;
• Seeking guidance from the CCO when in doubt regarding their regulatory obligations; and
• Escalating any violations or potential violations of applicable statutes, regulations, or rules, or the Company’s policies or procedures, to the CCO.
14. Corrective Action
Findings of non-compliance, compliance control gaps, and risks of non-compliance will be escalated to the Chief Compliance Officer. The Chief Compliance Officer will review the results of the Risk Assessment, ongoing monitoring and testing, the independent review, and reports from employees to identify compliance risks and findings of non-compliance or compliance gaps warranting corrective action.
If the Chief Compliance Officer determines that corrective action is warranted, the Chief Compliance Officer will work with the business line to create and implement a corrective action plan that adequately addresses the compliance gap or issue. Once the corrective action plan is executed, the new controls must be tested or otherwise vetted and approved by the Chief Compliance Officer to ensure that they adequately address the compliance gap or issue and are sustainable.
Compliance issues may be escalated to management and to the Board of Directors where it is deemed appropriate. Examples of issues that are appropriate for escalation include material violations of applicable law that may expose the Company to enforcement action or other liability, and repeat findings of non-compliance with applicable law or with this policy, among other things.
LAST UPDATED: April 6, 2020
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Terms and Conditions
$TSNP #HUMB AML Statement
As a global financial services company, HUMBL is committed to full compliance with all applicable laws and regulations regarding Anti- Money Laundering (“AML”). HUMBL’s policy is to prevent people engaged in money laundering, fraud, and other financial crimes, including terrorist financing, from using HUMBL’s services.
HUMBL has robust policies and procedures to detect, prevent and report suspicious activity. To comply with OFAC (Office of Foreign Asset Control) requirements, and global sanctions, we screen our customer accounts against government watch lists. In addition, we may request that you provide us with documentation to help prove your identity or for business verification purposes. We report suspicious transactions to the appropriate authorities in the respective country.
How does this impact me?
As part of our AML procedures, we collect information from you to satisfy our Know Your Customer requirements. This means that we may request information from you due to a specific identification requirement or as a result of our watch list screening process. We may ask you to provide documentation to help confirm your identity or provide additional information regarding your business. We may also request that you seek pre-approval for utilizing a HUMBL service if your account falls within a high risk compliance category.
When is this information requested?
We may ask for this information during account opening or as part of our account review process which we periodically conduct on our existing customers.
$TSNP #HUMBL Or Their Privacy Policy
HUMBL Privacy Statement
Overview
This privacy statement explains how and why HUMBL collects, stores, uses, and shares personal data when you visit our websites or use our services. Reading it will help you understand your privacy rights and choices.
“Personal data” in this statement means information about you, including your identity, finances, and online behavior.
“HUMBL” in this statement means HUMBL, Inc. This privacy statement only applies to the HUMBL and HUMBL services offered by HUMBL. To learn about our privacy practices for our other productsor services, like Venmo or Braintree, visit the website and review the privacy statement for that product or service.
Your privacy rights and choices
When it comes to how your personal data is collected, stored, used, and shared, you have rights and choices.?
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Understanding your rights
You have the right to request a copy of the personal data we’ve collected about you in the past 12months. You also have the right to ask us to delete your personal data we have collected about you. If you want to see or delete your personal data, contact us. We will not deny you services, charge you different prices, or provide you with a different level of service solely for exercising your privacy rights.
If you request to see or delete your personal data, we’ll first need to verify who you are before we can respond to your request. If we can’t verify your identity, we will not be able to fulfill your request.
If you want to delete your personal data, you have choices:
Log in to your account and delete information you previously added. For example, you can delete your profile picture and non-primary addresses in your settings
Call us and request that we delete specific information
Close your account
If you close your account or request that we delete personal data, we still need to keep some personal data so we can:
Complete a transaction, provide goods or services you requested, or comply with our promises to you in the User Agreement or other contract you have with us
Detect and prevent malicious, fraudulent, or illegal activity
Protect your (or another person’s) legal rights, including the right to free speech
Manage our internal business processes that are reasonably related to your expectations when using our services
Comply with laws
Depending on where you live and what type of account you use, you may have different rights and choices for managing your personal data. For example, certain State privacy laws do not apply to personal data collected, processed, or disclosed by a financial institution according to federal laws, such as the Gramm-Leach-Bliley Act. Consumers may read our Consumer Privacy Notice for more information about their rights under US federal law.?
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Understanding your choices
You can control how personal data is collected or shared, as well as how we communicate with you.Here are some of the ways you can customize your choices.
Choose how we collect personal data
You may choose to limit the personal data you provide when our apps or services request it. To help make choices that are right for you, it’s important to understand that persona ldata helps us provide a richer, more personalized experience for you. Also, some personal data is required for our services to function at all.
For example, sharing your contacts helps make it easier for you to find the people you want to send money to. If you choose not to share your contacts with us, you can still use our mobile apps, but some actions may not be as fast or easy as it would be if shared your contacts. Another example is creating an account with us. If you choose not to provide information that is required for an account to function, like your name and email address, we will not be able to create an account for you.
Choose how connected accounts collect and use personal data
If you connect your account to a third-party service, you may be able to manage how your personal data is collected, used, and shared by them. Read the third parties’ privacypolicies to see the choices they offer you.
You can control which third-party services you connect to your account and what personal data they can collect about you. For example, to manage the permissions, go to theSecurity settings in your HUMBL account.
Choose how we communicate with you
Your choices about how we communicate with you differ depending on the purpose of the message and how it is delivered. Some messages are considered optional and some are necessary foryou to manage your accounts with us. We use email, text messages, push notifications on your mobile device, and even paper mail depending on the situation and your preferences.
You can click the unsubscribe link in a marketing email, opt out of a text message by replying“STOP,” or turn off notifications on your device. You can also change your account’s notification settings or the notification preferences on your device.
You won’t be able to opt out of messages that are considered necessary for you to manage your account, such as receipts and emails that alert you to changes in your account’s statusthat require your attention. You may be able to decide how we send those messages, such as by email, text message, or a notification on your mobile device.
The personal data we collect
We may collect your personal data when you register for or use our services, such as when you create an account, make a payment, or make a purchase on a merchant’s website.
If you use our services without creating or logging into an account, we’ll still collect personal data, which may include your payment information, device information, and location.When you use our services without creating or logging into an account, we will use this information to process transactions, prevent fraud and comply with the law. We may connect this information with your account, if you have one or ifyou create an account at a later date.
Here are the kinds of personal data that we may collect when you create an account or use ours ervices:
1. Information that identifies you, for example:
First and last name
Address
Phone number
Email
IP address
Information collected from cookies or other tracking technologies
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2. Records and financial information, for example:
Social Security Number
Government-issued identification
Bank account and routing numbers
Credit and debit card information
Financial information
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3. Personal characteristics, for example:
Age
National origin
Disability
Citizenship
Military status
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4. Commercial information, for example:
Online shopping cart information
Purchase history
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5. Internet or network activity, for example:
Interactions with our services or sites
Shopping history
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6. Geolocation data, for example:
Global Positioning System (GPS) information when you give us permission through your device settings
IP-based geolocation
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7. Audio, electronic, visual, or similar information, for example:
Call recordings when you talk to customer service
Photo IDs and profile pictures you provide
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8. Professional or employment information, for example:
Business information, contact emails and phone numbers
Tax IDs
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9. Information we infer based on your personal data, for example:
Fraud and risk assessments
Personalization preferences
Where personal data comes from
We may collect personal information about you from various sources, for example from:
You
Merchants
Our payment partners, such as card networks and payment processors
Financial institutions, such as banks
Credit bureaus
Service providers, such as companies that help us manage risk and fraud, deliver services to you, and market our services
We do not knowingly collect personal information from people who are not allowed to use our sites and services, such as children under the age of 13.
?Contact us if you believe that we’ve mistakenly collected personal data from someone not allowed to use our services. We’ll delete it immediately, unless we’re legally required to keep it.
How we use tracking technologies like cookies
We or our authorized service providers may use cookies and similar tracking technologies to collect personal data whenever you use our services, visit our sites, or visit websites that offer our services. The information collected with these technologies helps us personalize your experience, measure the effect of our ads, prevent fraud and enhance the security of our sites and service.
You can disable or decline some cookies for our sites and services. But, since some parts of our service rely on cookies to work, those services could become difficult or impossible to use.
Some web browsers have an optional setting called “Do Not Track” (DNT) that lets you opt-out of being tracked by advertisers and some third parties. Because many of our services won’t function without tracking data, we do not respond to DNT settings.
If you want to know more about how we use cookies, read our
?Cookie Statement. To learn how to opt-out of this kind of tracking technology, visit About Ads.
Why we collect personal data
We collect personal data for many reasons, including to improve your experience, and to run our business. Specific reasons why we collect your personal data include:
Run our sites and provide better services, for example to help you send or request money, make purchases, show you your account information, verify access to your account, and keep your account and payment information up to date.
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Manage and improve our business. For example, we do user research to improve our products’ performance and abilities. We also monitor and analyze our sites to help ensure they work as expected.
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Protect our business and our customers from risk and fraud, including fraud that involves our business partners, strategic ventures, or other individuals and merchants, such as eBay, Inc.
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Send you marketing information about our products and services. We may use personal data to market about our partners, such as merchants. We use personal data to better understand and cater to your interests.
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Personalize your experience when you use our sites and services, as well as other third-party sites and services. In this case, we might use tracking technologies like cookies. See our Cookie Statement for more details.
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Send you locally relevant options, but only if you agree to let us track your location. If you do, this can help us enhance the security of our sites and services, and customize our services by using the right language and personalizing content such as ads and search results.
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Make it easy for you to find and connect with others. For instance, if you let us access your contacts, we can suggest connections with people you may know.
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Contact you when you need us, such as answering a question you sent to our customer service team.
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Comply with laws and enforce our agreements with you and other people who use our services.
How and why we share personal data
We do not sell your personal data. However, we may share personal data across our services and with other members of the HUMBL corporate family. Sometimes we share the personaldata we collect with third parties to help us provide services, protect our customers from risk and fraud, market our products, and comply with legal obligations.
You can review the personal data that we may share by reviewing The personal data we collect section.
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We may share personal data with:
1. Other members of the HUMBL corporate family
2. Service providers that help us with processing payments, marketing, research, compliance, audits, corporate governance, communications, and security
3. Card networks and payment processors
4. Financial institutions, such as banks we partner with to offer joint products, likeSynchrony Bank in connection with HUMBL Credit, the HUMBL Cashback Mastercard, and the HUMBL Extras Mastercard
5. Credit reporting and collections agencies
6. Courts, governments, regulators and law enforcement when accompanied by a subpoena or other legal documentation that requires HUMBL or members of our corporate family to respond
7. People involved in a transaction, such as other users or merchants and their service providers.
8. Third parties that you asked us to connect with, such as other financial or social media apps. If you want us to stop sharing information with a third party, disconnect your account from that third party.
9. Third-party tools used to help fight spam and abuse. For instance, we use ReCaptcha to help determine whether you’re a person or a computer. When you use ReCaptcha, your personal data is subject to Google’s Privacy Policy and Terms of Use.
10. Other third parties to:
o Comply with laws
o Investigate or enforce violations of our user agreement
o Facilitate a merger, purchase, or sale of part or all of our business
o Comply with card association rules
o To prevent physical harm or illegal activity
How we protect your personal data
Helping to keep your personal data safe against loss, misuse, unauthorized access, disclosure, and alteration is our top priority.
To protect your personal data, we use technical, physical, and administrative security measures that include:
Firewalls
Data encryption
Physical access controls at our data centers
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While we protect our systems and services, you’re responsible for keeping your password(s) and account information private. You are also responsible for making sure your personal information is accurate and up to date.
If your account is closed, we may keep your personal data and other information as required by law and according to our data retention policy. If we do, we’ll continue to handle it as we describe in this statement.
How this statement changes over time
We’ll make changes tot his privacy statement from time to time. This helps us stay up to date with changes to our business and the most current laws. After a new version is published, we’ll collect, store, use, and protect your personal data as we outline in that revised statement.
If the new version reduces your rights or increases your responsibilities, we’ll post it on the Policy Updates or Privacy Statement page of our website at least 21 days before it becomes effective.
We may notify you about these changes through email or other communications.
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Contact Us
If you have questions about this privacy statement or your personal data, contact us so we can help.
To talk about your HUMBL account:
Call or email HUMBL Customer Service
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$TSNP #HUMBL HAs everyone read their USER Agreement?
HUMBL User Agreement
Overview
This privacy statement explains how and why HUMBL collects, stores, uses, and shares personal data when you visit our websites or use our services. Reading it will help you understand your privacy rights and choices.
“Personal data” in this statement means information about you, including your identity, finances, and online behavior.
“HUMBL” in this statement means HUMBL, Inc. This privacy statement only applies to the HUMBL and HUMBL services offered by HUMBL. To learn about our privacy practices for our other productsor services, like Venmo or Braintree, visit the website and review the privacy statement for that product or service.
Your privacy rights and choices
When it comes to how your personal data is collected, stored, used, and shared, you have rights and choices.?
?
Understanding your rights
You have the right to request a copy of the personal data we’ve collected about you in the past 12months. You also have the right to ask us to delete your personal data we have collected about you. If you want to see or delete your personal data, contact us. We will not deny you services, charge you different prices, or provide you with a different level of service solely for exercising your privacy rights.
If you request to see or delete your personal data, we’ll first need to verify who you are before we can respond to your request. If we can’t verify your identity, we will not be able to fulfill your request.
If you want to delete your personal data, you have choices:
Log in to your account and delete information you previously added. For example, you can delete your profile picture and non-primary addresses in your settings
Call us and request that we delete specific information
Close your account
If you close your account or request that we delete personal data, we still need to keep some personal data so we can:
Complete a transaction, provide goods or services you requested, or comply with our promises to you in the User Agreement or other contract you have with us
Detect and prevent malicious, fraudulent, or illegal activity
Protect your (or another person’s) legal rights, including the right to free speech
Manage our internal business processes that are reasonably related to your expectations when using our services
Comply with laws
Depending on where you live and what type of account you use, you may have different rights and choices for managing your personal data. For example, certain State privacy laws do not apply to personal data collected, processed, or disclosed by a financial institution according to federal laws, such as the Gramm-Leach-Bliley Act. Consumers may read our Consumer Privacy Notice for more information about their rights under US federal law.?
?
Understanding your choices
You can control how personal data is collected or shared, as well as how we communicate with you.Here are some of the ways you can customize your choices.
Choose how we collect personal data
You may choose to limit the personal data you provide when our apps or services request it. To help make choices that are right for you, it’s important to understand that persona ldata helps us provide a richer, more personalized experience for you. Also, some personal data is required for our services to function at all.
For example, sharing your contacts helps make it easier for you to find the people you want to send money to. If you choose not to share your contacts with us, you can still use our mobile apps, but some actions may not be as fast or easy as it would be if shared your contacts. Another example is creating an account with us. If you choose not to provide information that is required for an account to function, like your name and email address, we will not be able to create an account for you.
Choose how connected accounts collect and use personal data
If you connect your account to a third-party service, you may be able to manage how your personal data is collected, used, and shared by them. Read the third parties’ privacypolicies to see the choices they offer you.
You can control which third-party services you connect to your account and what personal data they can collect about you. For example, to manage the permissions, go to theSecurity settings in your HUMBL account.
Choose how we communicate with you
Your choices about how we communicate with you differ depending on the purpose of the message and how it is delivered. Some messages are considered optional and some are necessary foryou to manage your accounts with us. We use email, text messages, push notifications on your mobile device, and even paper mail depending on the situation and your preferences.
You can click the unsubscribe link in a marketing email, opt out of a text message by replying“STOP,” or turn off notifications on your device. You can also change your account’s notification settings or the notification preferences on your device.
You won’t be able to opt out of messages that are considered necessary for you to manage your account, such as receipts and emails that alert you to changes in your account’s statusthat require your attention. You may be able to decide how we send those messages, such as by email, text message, or a notification on your mobile device.
The personal data we collect
We may collect your personal data when you register for or use our services, such as when you create an account, make a payment, or make a purchase on a merchant’s website.
If you use our services without creating or logging into an account, we’ll still collect personal data, which may include your payment information, device information, and location.When you use our services without creating or logging into an account, we will use this information to process transactions, prevent fraud and comply with the law. We may connect this information with your account, if you have one or ifyou create an account at a later date.
Here are the kinds of personal data that we may collect when you create an account or use ours ervices:
1. Information that identifies you, for example:
First and last name
Address
Phone number
Email
IP address
Information collected from cookies or other tracking technologies
?
2. Records and financial information, for example:
Social Security Number
Government-issued identification
Bank account and routing numbers
Credit and debit card information
Financial information
?
3. Personal characteristics, for example:
Age
National origin
Disability
Citizenship
Military status
?
4. Commercial information, for example:
Online shopping cart information
Purchase history
?
5. Internet or network activity, for example:
Interactions with our services or sites
Shopping history
?
6. Geolocation data, for example:
Global Positioning System (GPS) information when you give us permission through your device settings
IP-based geolocation
?
7. Audio, electronic, visual, or similar information, for example:
Call recordings when you talk to customer service
Photo IDs and profile pictures you provide
?
8. Professional or employment information, for example:
Business information, contact emails and phone numbers
Tax IDs
?
9. Information we infer based on your personal data, for example:
Fraud and risk assessments
Personalization preferences
Where personal data comes from
We may collect personal information about you from various sources, for example from:
You
Merchants
Our payment partners, such as card networks and payment processors
Financial institutions, such as banks
Credit bureaus
Service providers, such as companies that help us manage risk and fraud, deliver services to you, and market our services
We do not knowingly collect personal information from people who are not allowed to use our sites and services, such as children under the age of 13.
?Contact us if you believe that we’ve mistakenly collected personal data from someone not allowed to use our services. We’ll delete it immediately, unless we’re legally required to keep it.
How we use tracking technologies like cookies
We or our authorized service providers may use cookies and similar tracking technologies to collect personal data whenever you use our services, visit our sites, or visit websites that offer our services. The information collected with these technologies helps us personalize your experience, measure the effect of our ads, prevent fraud and enhance the security of our sites and service.
You can disable or decline some cookies for our sites and services. But, since some parts of our service rely on cookies to work, those services could become difficult or impossible to use.
Some web browsers have an optional setting called “Do Not Track” (DNT) that lets you opt-out of being tracked by advertisers and some third parties. Because many of our services won’t function without tracking data, we do not respond to DNT settings.
If you want to know more about how we use cookies, read our
?Cookie Statement. To learn how to opt-out of this kind of tracking technology, visit About Ads.
Why we collect personal data
We collect personal data for many reasons, including to improve your experience, and to run our business. Specific reasons why we collect your personal data include:
Run our sites and provide better services, for example to help you send or request money, make purchases, show you your account information, verify access to your account, and keep your account and payment information up to date.
?
Manage and improve our business. For example, we do user research to improve our products’ performance and abilities. We also monitor and analyze our sites to help ensure they work as expected.
?
Protect our business and our customers from risk and fraud, including fraud that involves our business partners, strategic ventures, or other individuals and merchants, such as eBay, Inc.
?
Send you marketing information about our products and services. We may use personal data to market about our partners, such as merchants. We use personal data to better understand and cater to your interests.
?
Personalize your experience when you use our sites and services, as well as other third-party sites and services. In this case, we might use tracking technologies like cookies. See our Cookie Statement for more details.
?
Send you locally relevant options, but only if you agree to let us track your location. If you do, this can help us enhance the security of our sites and services, and customize our services by using the right language and personalizing content such as ads and search results.
?
Make it easy for you to find and connect with others. For instance, if you let us access your contacts, we can suggest connections with people you may know.
?
Contact you when you need us, such as answering a question you sent to our customer service team.
?
Comply with laws and enforce our agreements with you and other people who use our services.
How and why we share personal data
We do not sell your personal data. However, we may share personal data across our services and with other members of the HUMBL corporate family. Sometimes we share the personaldata we collect with third parties to help us provide services, protect our customers from risk and fraud, market our products, and comply with legal obligations.
You can review the personal data that we may share by reviewing The personal data we collect section.
?
We may share personal data with:
1. Other members of the HUMBL corporate family
2. Service providers that help us with processing payments, marketing, research, compliance, audits, corporate governance, communications, and security
3. Card networks and payment processors
4. Financial institutions, such as banks we partner with to offer joint products, likeSynchrony Bank in connection with HUMBL Credit, the HUMBL Cashback Mastercard, and the HUMBL Extras Mastercard
5. Credit reporting and collections agencies
6. Courts, governments, regulators and law enforcement when accompanied by a subpoena or other legal documentation that requires HUMBL or members of our corporate family to respond
7. People involved in a transaction, such as other users or merchants and their service providers.
8. Third parties that you asked us to connect with, such as other financial or social media apps. If you want us to stop sharing information with a third party, disconnect your account from that third party.
9. Third-party tools used to help fight spam and abuse. For instance, we use ReCaptcha to help determine whether you’re a person or a computer. When you use ReCaptcha, your personal data is subject to Google’s Privacy Policy and Terms of Use.
10. Other third parties to:
o Comply with laws
o Investigate or enforce violations of our user agreement
o Facilitate a merger, purchase, or sale of part or all of our business
o Comply with card association rules
o To prevent physical harm or illegal activity
How we protect your personal data
Helping to keep your personal data safe against loss, misuse, unauthorized access, disclosure, and alteration is our top priority.
To protect your personal data, we use technical, physical, and administrative security measures that include:
Firewalls
Data encryption
Physical access controls at our data centers
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While we protect our systems and services, you’re responsible for keeping your password(s) and account information private. You are also responsible for making sure your personal information is accurate and up to date.
If your account is closed, we may keep your personal data and other information as required by law and according to our data retention policy. If we do, we’ll continue to handle it as we describe in this statement.
How this statement changes over time
We’ll make changes tot his privacy statement from time to time. This helps us stay up to date with changes to our business and the most current laws. After a new version is published, we’ll collect, store, use, and protect your personal data as we outline in that revised statement.
If the new version reduces your rights or increases your responsibilities, we’ll post it on the Policy Updates or Privacy Statement page of our website at least 21 days before it becomes effective.
We may notify you about these changes through email or other communications.
$TSNP #HUMBL WEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEE!!!!
$TSNP they are getting the house in order!!!
TSNP SECURITY DETAILS
Share Structure
Market Cap Market Cap
72,319,228
11/17/2020
Authorized Shares
5,000,000,000
11/17/2020
Outstanding Shares
3,996,709,773
11/17/2020
Restricted
360,955,260
11/17/2020
Unrestricted
3,635,754,513
11/17/2020
Held at DTC
3,218,397,783
11/17/2020
Float
3,635,754,513
06/18/2020
Par Value
0.001
https://www.otcmarkets.com/stock/TSNP/security
NICE!!!
Looks like they did their DD last night...SMART!
L2 please my app is down.. ty
Great perception as you have been doing astonishing well for over 20 years calling OTC plays.... This one we will be talking about through the decade!
God bless you and all the DD you do for those who are too lazy or have inexperience on doing it for themselves.
Myself personally....I doubled my position yesterday and now have over $100k in this one... that's how confident I am....even going to go do some work today outside for my therapy.....I have to calm myself down after making almost $200,000 in just over a week....I'm a definite risk taker but when I see a winner, I play it through the end...most of the time. Glut and everyone
Let's all have a great roast of the week/month/year....remember this .. .their are millions out their who lost their jobs bc of covid and the flocked to the stocks...but most of them are in the mid and large cap....we need to being them all here to where the big $ with small investments are made!
Mark Turner
Cyber Security | Security Engineering Senior Global Leader at ViaSat Inc.
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Mark Turner
Popoola Ayo
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Co-Founder /Business Development and Strategy Consultant.
Colombia 500+ connections Contact info
ONYX International/ ONYX LABS
University of California, Berkeley
Experienced Founding partner and Global Consultant with a demonstrated history of working in the Information Technology, Financial Technology, Blockchain,(DLT) and Digital Asset services industry. Skilled in Negotiation, Business Planning an development, Analytical Skills, Management, and Start-ups. Crypto Asset /Token economies, DeFi, Strong entrepreneurship professional and graduate from University of California, Berkeley.
Certified Blockchain Expert (CBE) from Blockchain Council.
Adam Wolfe
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Tech Lead
Los Angeles Metropolitan Area 500+ connections Contact info
HUMBL LLC
California State University-Long Beach
About
I'm having a blast building global financial products. At HUMBL we are building a global mobile financial ecosystem. At Block 30 Labs we are developing blockchain based payment systems and origin tracking.
When I was 6 years old, my dad showed me that you could connect a 9 volt battery to an LED and a small motor and they came to life. That left a lifelong desire in me to make something, anything. Now, with a talented team, I get to make cool apps that can benefit people globally.
CTO
Company Name HUMBL LLC
Dates Employed Jan 2020 – Present
Employment Duration 11 mos
LocationSan Diego, California, United States
• Leading development of the global HUMBL mobile financial ecosystem
• Architecting flexible microservice based designs
• Guiding a team of talented developers
• Nurturing an inclusive and open company culture
Karen G.
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Co-Founder- VP, Global Sales and Partners - HUMBL
San Diego, California, United States 196 connections Contact info
HUMBL
San Diego State University
About
Results-driven development and sales management professional with 25+ years of leadership experience among Fortune 500 companies. Experience emphasis in partnership development, building global teams, training and profitability process improvement.
Michele Rivera
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Michele Rivera
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Co-Founder / VP Global Partnerships
San Diego County, California, United States 477 connections Contact info
HUMBL LLC
About
Experienced Leader: 25-year career working in General Management and customer service for some of the world’s leading consumer brands including Disney and the Williams-Sonoma family of companies. Led teams of over 100 + people, performing national sales training, retail development & management, new store openings, guest relations, and hospitality.
Jeffrey Hinshaw, M.B.A.
Co-Founder + COO of HUMBL | Owner / Investor in several FinTech, Blockchain, & Biomechanics companies
Jeffrey Hinshaw, M.B.A.
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Jeffrey Hinshaw, M.B.A.
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Co-Founder + COO of HUMBL | Owner / Investor in several FinTech, Blockchain, & Biomechanics companies
San Diego, California, United States 500+ connections Contact info
HUMBL LLC
San Diego State University-California State University
About
Jeffrey Hinshaw has successfully combined his strong research and academic based way of solving problems to his many professional and entrepreneurial successes.
He is Co-Founder + Chief Operating Officer at BLOCK 30 Labs which is a network of technologists, researchers, financial engineers and academics working on blockchain innovations. They recently launched the BLOCK 30 Index which aims to bridge the gap between traditional finance & digital assets by providing a central framework for global media, investors, financial institutions, and the government to track the digital asset market.
He is one of the owners of Balance Tracking Systems, which produces a portable force plate used to assess balance for fall risk analysis, concussion management, and athletic research.
He is also an owner of ABC Mining, a digital asset mining company that is focused on extensive data and financial analytic research for their clients.
Jeff is an active member of multiple angel investor and venture capital groups. He has also held both consultant and analytical roles at two Fortune 500s.
He is a current faculty member at SDSU teaching two classes. He has two master’s degrees from SDSU: an MBA in Finance, and a Master’s in Kinesiology where he specialized in Biomechanics. He was also a graduate researcher in SDSUs Biomechanics lab for two years, where he became a published scientific author.