DATA & PRIVACY PROTECTION

FRAMEWORK OVERVIEW

JPMTG maintains a proprietary Legal, Jurisdictional & Protective Framework covering corporate governance, intellectual property, trade secrets, and personal data protection across its U.S. and Swiss operations.

DATA & PRIVACY PROTECTION

The framework provides for:

• Controlled, documented, and traceable processing of personal and corporate information
• Preservation and integrity of relevant evidence and records
• Compliance with applicable Swiss and U.S. data protection requirements
• Appropriate consideration of the Swiss Federal Act on Data Protection (FADP/nFADP)
• Swiss–U.S. Data Privacy Framework (Swiss–U.S. DPF) compliance for cross-border transfers
• Structured legal and evidentiary response in the event of unauthorized access or misuse

SWISS–U.S. DATA PRIVACY FRAMEWORK

The Swiss–U.S. DPF provides a legal framework for the transfer and protection of personal data between Switzerland and participating U.S. organizations. Applicable since 15 September 2024, it offers individuals in Switzerland specific avenues of redress concerning certified U.S. organizations.

RELEVANT AUTHORITIES

• Federal Data Protection and Information Commissioner (FDPIC/PFPDT)
• U.S. Department of Commerce – International Trade Administration (ITA)
• U.S. Federal Trade Commission (FTC), where applicable
• IRS Tax Information Confidentiality — 26 U.S.C. § 6103

PURPOSE & SCOPE

This framework provides a documented, controlled, and traceable structure for protecting the legitimate interests of Newport Enterprises Group LLC and relevant data subjects, in the interest of transparency, accountability, and sound corporate governance.