At CONFIDES BVBA (hereinafter referred to as the "Company") we recognize that privacy is important to you.

This Privacy Policy explains how the Company and all its affiliates collect, use and disclose your personal data, and your rights in relation to the personal data as these are held. Keeping your data secure and private is part of our philosophy for delivering high standards of services.

In this privacy policy, “us’, “we’, “our” is the data controller of your personal data and is subject to the EU General Data Protection Regulation 2016/679 (“GDPR”) and any locally applicable data protection laws.

How we collect your data

We collect your personal data in the manner described below:

• From information about you provided to us by you directly;

• When you communicate with us in writing, by telephone, fax, website registration, email or other digital means. In this respect, we may monitor, record and store any such communication;

• When you complete (or we complete on your behalf) client on-boarding or application or forms;

• Through our mobile applications and/or software developed by the Company

Data we collect

We collect the following categories of personal data about you:

• Your name and contact information such as your home or business address, profession, email address and telephone number;

• Biographical information which may confirm your identity including your date of birth, and your passport number or national identity card details, and/or your nationality along with the relevant copies of the aforementioned documentation, training data, health & injury profile data ; and

• Information about your employment, education, family or personal circumstances, and interests, where relevant;

Processing your personal data

1. Performance of a contract with you

We process your personal data because it is necessary for the performance of a services provision agreement to which you are a party or in order to take steps at your request prior to entering into such agreement or it is necessary for the proper functioning of an application or algorithm or program developed by the Company and the data generation.

In this respect, we use your personal data for the following:

• To provide you with the services as set out in our services agreement with you

• For any other purpose for which you provide us with your personal data.

In this respect, we may share your personal data with the following:

• Third parties whom we engage to assist in delivering the services to you, including other affiliates of the Company;

• Our professional advisers where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, IT;

• The courts of the Republic of Cyprus and/or any other public authorities of the Republic of Cyprus, or where requested, either by Law or by agreement, for providing our services to you.

2. Legitimate interests

We also process your personal data because it is necessary for our legitimate interests, or sometimes where it is necessary for the legitimate interests of another person.

In this respect, we use your personal data for the following:

• For marketing to you. In this respect, see the separate section on Marketing below;

• Training our staff or monitoring their performance;

• For the administration and management of our business and archiving or statistical analysis;

• Seeking advice on our rights and obligations, such as where we require our own legal advice.

In this respect we will share your personal data with the following:

• Our advisers or agents where it is necessary for us to obtain their advice or assistance;

• With third parties and their advisers where those third parties are acquiring, or considering acquiring, all or part of our business.

3. Consent

We may rely on your freely given consent at the time you provided your personal data to us either in writing or by using an application or software of the Company for a purpose of the process other than for the purposes set out hereinabove, then the lawfulness of such processing is based on that consent. You have the right to withdraw consent at any time. However, any processing of personal data will not be affected prior to the receipt of the withdrawal.

4. Compliance with legal obligations

We also process your personal data for our compliance with a legal obligation which we are under.

In this respect, we will use your personal data for the following:

• As required by tax authorities or any competent court or legal authority under the relevant laws.

In this respect, we will share your personal data with the following:

• Our advisers where it is necessary for us to obtain their advice or assistance;

• Our auditors where it is necessary as part of their auditing functions;

• Our affiliates who are assisting us in processing any personal data for statistical analysis.

• With relevant regulators or law enforcement agencies where we are required to do so under relevant laws.

Marketing

We may send you marketing about services we provide which may be of interest to you, as well as other information in the form of alerts, newsletters and invitations to events or functions which we believe might be of interest to you or in order to update you with information (such as legal or commercial news) which we believe may be relevant to you.

Your data is not shared outside of CONFIDES.

We will communicate this to you in a number of ways including by post, telephone, email or other digital channels.

If you object to receiving marketing from us at any time, please contact us by email: confides@telenet.be

If you have given consent and you wish to withdraw it at any time, please contact us on the above e-mail.

Transfer and processing of your personal data outside the European Union

When sharing your personal data with third parties as set out in this Privacy Policy, it may be transferred outside the European Union. Such third parties have access to personal data solely for the purposes of performing the services specified in the applicable service agreement, and not for any other purpose. In these circumstances, your personal data will only be transferred on one of the following cases:

• The country that we send the personal data to is approved by the European Commission as providing an adequate level of protection for personal data;

• The transfer is to a recipient in the United States of America who has registered under the EU/US Privacy Shield;

• The recipient has entered into European Commission standard contractual clauses with us or contract terms ensuring adequate data protection; or

• You have explicitly consented to the same.

Retention of your data

Your contact information and personal data are stored securely, using a mixture of encryption, password protection, and servers/back-ups all kept with multiple lock protection.

We have put in place appropriate technical and organisational measures including physical, electronic and procedural measures to protect personal data from loss, misuse, alteration or destruction. We restrict access to information at our offices so that only officers and/or employees who need to know the information have access to it. Those individuals who have access to the data are required to maintain the confidentiality of such information. Please be aware that users should also take care with how they handle and disclose their personal data and should avoid sending personal data through insecure email.

Your rights under GDPR

Under the GDPR you have the following rights:

• To obtain access to, and copies of, the personal data that we hold about you;

• To require that we cease processing your personal data if the processing is causing you damage or distress;

• To require us not to send you marketing communications;

• To require us to erase your personal data;

• To require us to restrict our data processing activities;

• To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller; and

• To require us to correct the personal data we hold about you if it is incorrect.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

Data Protection Officer

We have designated a Data Protection Officer (“DPO”), who is responsible to monitor compliance with this privacy policy as well as the applicable Laws and liaise with the relevant authorities.

The DPO may be contacted directly with regards to all matters concerning this policy and the processing of your personal data including the enforcement of all applicable and available rights.

Official requests may be made electronically at: confides@telenet.be

For any complaints you may have you may contact the Data Commissioner of the Republic of Cyprus at http://www.dataprotection.gov.cy

Changes to this policy

Please note that this Privacy Policy may change from time to time. However, we will not reduce your rights under this Policy without your explicit consent. Any Policy changes will be duly posted on this page and each version of this Policy will be identified at the top of the page by its effective date.