Privacy Policy

359 Solutions, LLC ("359 Solutions," "we," "us," or "our") is committed to protecting the privacy and confidentiality of our clients and the individuals whose information we handle in the course of providing our services. This Privacy Policy describes how we collect, use, disclose, and safeguard personal information in connection with our business operations.

359 Solutions operates in a manner consistent with applicable federal privacy and data security requirements, including but not limited to guidance issued by the Federal Financial Institutions Examination Council (FFIEC), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the Federal Trade Commission (FTC). Our information security program is designed in alignment with the NIST Cybersecurity Framework (CSF) 2.0.

By engaging our services, you acknowledge and agree to the practices described in this Privacy Policy.

This Privacy Policy applies to:

• All clients and prospective clients of 359 Solutions, LLC;
• All individuals whose personal information is received, processed, or maintained by 359 Solutions in the course of providing professional services;
• All employees, contractors, and agents of 359 Solutions who access or process personal information on our behalf.

This Policy applies to information collected through our website, email communications, service engagements, and any other means by which personal information is received.

3.1 Information You Provide

We may collect personal information that you voluntarily provide to us, including:

• Contact information such as name, business address, email address, and telephone number;
• Business and organizational information necessary for service delivery;
• Financial account and transaction information provided in connection with our services;
• Communications and correspondence with our personnel.

3.2 Information Collected Automatically

When you interact with our website or electronic communications, we may collect certain technical information, including:

• IP address and browser type;
• Pages visited and time spent on our website;
• Referring URLs and clickstream data.

This information is collected solely for security monitoring, service improvement, and compliance purposes.

3.3 Information from Third Parties

In the course of providing services, we may receive personal information from third parties such as financial institutions, regulators, or other authorized parties. Such information is handled with the same level of care and protection as information we collect directly.

359 Solutions uses personal information solely for legitimate business purposes directly related to the delivery of our professional services. Specifically, we use information to:

• Provide, manage, and improve our professional services;
• Communicate with clients regarding service matters;
• Comply with applicable federal and state laws, regulations, and regulatory guidance;
• Protect against fraud, unauthorized access, and other security threats;
• Maintain accurate business records as required by law or regulation;
• Respond to lawful requests from government authorities or regulators.

359 Solutions does not sell, trade, or otherwise transfer your personal information to outside parties. We may disclose personal information only under the following limited circumstances:

5.1 Service Providers

We may engage trusted third-party service providers who assist us in operating our business, provided that such parties agree to maintain the confidentiality and security of the information and are prohibited from using it for any other purpose.

5.2 Legal and Regulatory Requirements

We may disclose personal information as required by law, regulation, or regulatory examination, or in response to a valid legal process such as a subpoena, court order, or government inquiry, including requests from the FFIEC, FDIC, OCC, FTC, or other applicable regulatory authorities.

5.3 Protection of Rights

We may disclose information where necessary to protect the rights, property, or safety of 359 Solutions, our clients, or others, or to prevent or detect fraud or other unlawful activity.

5.4 Business Transfers

In the event of a merger, acquisition, or sale of all or a portion of our business assets, personal information may be transferred as part of that transaction. We will notify affected individuals in the event of a material change in how their information is handled.

359 Solutions maintains a comprehensive information security program consistent with the NIST Cybersecurity Framework (CSF) 2.0, encompassing the core functions of Govern, Identify, Protect, Detect, Respond, and Recover. Our administrative, technical, and physical safeguards are designed to protect personal information against unauthorized access, disclosure, alteration, and destruction.

Key elements of our security program include:

• Access controls limiting information access to authorized personnel on a need-to-know basis;
• Encryption of sensitive data in transit and at rest;
• Regular risk assessments and vulnerability management activities;
• Security awareness training for all personnel;
• Incident response and breach notification procedures;
• Vendor management and third-party risk oversight.

While we employ reasonable safeguards, no security program can guarantee absolute protection. We encourage clients to take appropriate steps to protect their own information.

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, and as required by applicable laws, regulations, and regulatory guidance. Retention periods are determined by the nature of the information and the applicable legal or regulatory framework. When personal information is no longer required, we dispose of it in a secure manner consistent with our data disposal policies.

Depending on applicable law and the nature of your relationship with us, you may have certain rights regarding your personal information, including the right to:

• Request access to the personal information we hold about you;
• Request correction of inaccurate or incomplete information;
• Request deletion of your personal information, subject to applicable legal and regulatory retention obligations;
• Opt out of certain uses of your information, to the extent permitted by law.

To exercise any of the above rights, please contact us using the information provided in Section 11 of this Policy. We will respond to your request in accordance with applicable legal requirements.

Our website may contain links to third-party websites. 359 Solutions is not responsible for the privacy practices or content of such third-party sites. We encourage you to review the privacy policies of any third-party websites you visit.

359 Solutions reserves the right to update or modify this Privacy Policy at any time. Material changes will be communicated to clients through appropriate means, such as email notification or posting of a revised policy on our website. The effective date at the top of this document will be updated to reflect any revisions. Your continued engagement with our services following notification of changes constitutes acceptance of the revised Policy.

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at: