We will not in the normal course transfer Personal Data outside the European Economic Area (EEA) save in exceptional circumstances and in all such cases appropriate safeguards shall be put in place to protect the Personal Data when it is outside the EEA. Such safeguards may include the Standard Data Protection Clauses (also known as EU Model Clauses). Further details are here: http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm. Transfers may also happen based on the US Privacy Shield. Details here: https://www.privacyshield.gov/welcome. Where applicable, individuals may request a copy of the EU Model Clauses by contacting the HBFI’s DPO (contact details below).