Verlinvest Group SA (Place Eugene Flagey 18, 1050 Brussels) and its wholly owned subsidiaries (collectively “Company”, “we”, “us”, “our”) are committed to safeguarding the personal data it processes in connection with its business in accordance with fair information practices and applicable data privacy laws.

1. Scope

This notice (“Privacy Notice”) explains how the Company, acting as data controller, handles the personal data of business contacts as well as services providers, agents, consultants, and website visitors (“you”, “your”), in the course of its activities.

2. Personal Data We Collect

We collect your personal data when at the occasion of business events, meetings, networking events, public searches on professional or social-media databases or other similar occurrences you access our offices or provide us or publicly disclose personal data. We collect your personal data for the purpose of current or future business relationships with you and for the purposes specified below. We collect personal data, either directly from you or from third parties including public databases or social media platforms. We collect, use and transfer your personal data through security cameras and automated and/or paper-based data processing systems. We have established routine processing functions. In the normal course of activities, we collect the following types of personal data:

• Contact information, such as your name, home and professional address, email address, date of birth, gender, phone number and images taken by security cameras;
• Due diligence information in connection with an actual or prospective corporate transaction or investment, including information about your employer, your own company, your business and your contacts;
• Relationship information that helps us do business with you and contact preferences; or
• Compliance and risk management information, such as information for fraud prevention.

3. Use of Your Personal Data

We use your personal data for the following purposes:

• Fulfilling our legal obligations;
• Managing your ongoing relationship with us, including communicating with you;
• Providing and improving our business operations;
• Legal defense and compliance, including compliance with government authority requests for information, liens, garnishments and tax compliance;
• Internal reporting and auditing; and Protection of the Company, its workforce and the public against injury, theft, legal liability, fraud, abuse, or threat to the security of our networks, communications, systems, facilities and infrastructure.

We use the following legal bases for the processing of your personal data:

• Compliance with a legal obligation to which we are subject;
• The need to process your personal data for contract performance or to take steps to enter into a contract with you;
• Where the processing is necessary for our legitimate business interests including notification of an investment/divestment opportunity, due diligence activities, professional advice or input in relation to an investment/divestment or with respect to one of our portfolio companies, professional advice in connection with the Company’s business or its employees, operating our business properly, conducting marketing and protecting against fraud and other liabilities, ensuring compliance and our ability to assert legal defenses, guarantying the security of our networks and systems, and protecting our assets; and
• Your consent, in some specific circumstances.

4. Disclosures and Categories of Recipients

We have taken measures to ensure that your personal data is processed in a manner that is compatible with the purposes indicated above. For the stated purposes, your personal data may be disclosed to, or received from, the following parties:

• Other Company entities, joint ventures, subcontractors, vendors or suppliers who perform services on our behalf for the aforementioned purposes;
• A newly formed or acquiring organization if the Company is involved in a merger, sale or a transfer of some or all of its business;
• Certain service providers as necessary to fulfill the aforementioned purposes, such as data hosting providers;
• Any recipient, if we are legally required to do so, such as by court order or applicable law; or
• Any recipient when reasonably necessary such as in the event of a life-threatening emergency.

5. International Transfers

We may transfer your personal data to countries that have not been found by the European Commission to provide adequate protection. Where such transfers occur, we will ensure that adequate protection exists either through appropriate contractual arrangements or as required by law.

6. Information Security

We take precautions to protect personal data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We have taken appropriate technical and organizational measures to protect the information systems on which your personal data is stored, and we contractually require our suppliers and service providers to protect your personal data.

7. Your Personal Data Rights

You have the right to:

• Access your personal data and to learn the origin of the data, the details of the data controller(s), the data processor(s) and the parties to whom the data may be disclosed;
• Withdraw your consent at any time where your personal data is processed with your consent;
• Update or correct your personal data so that it is always accurate;
• Delete your personal data from our records if it is no longer needed for the purposes indicated in this notice;
• Restrict the processing of your personal data in certain circumstances, such as where you have contested the accuracy of your personal data, for the period enabling us to verify its accuracy;
• Object to us processing your personal data or to tell us to stop processing your personal data. Once you have informed us of this request, we shall no longer process your personal data unless permitted by law; and
• Obtain your personal data in an electronic format and to request that we transmit this data to another company.
  You may exercise these rights free of charge. However, Verlinvest may charge a reasonable fee or refuse to act on a request if it is manifestly unfounded or excessive, in particular because of its repetitive character. In some situations, Verlinvest may refuse to act or may impose limitations on your rights if, for instance, your request is likely to adversely affect the rights and freedoms of others, prejudice the execution or enforcement of the law, interfere with pending or future litigation or infringe applicable law.

If you wish to exercise any of these rights or have any complaints, please contact us using the details provided under “How to Contact Us” below. You also have the right to file a complaint with the relevant data protection authority.

8. Personal Data Retention

Your personal data will be retained as long as necessary to achieve the business purposes stated in this notice, or in accordance with our legal and regulatory obligations. Our retention policies reflect applicable local statute of limitation periods and legal requirements

9. Cookies and linked sites

When you visit our website, we may collect certain information by automated means, using technologies such as cookies or pixel tags. Cookies are small text files created by a web server that can be stored on your device. In most instances, the information we collect using cookies or similar technologies is used in a non-identifiable way. You can learn more about cookies and how to manage them at www.allaboutcookies.org and www.youronlinechoices.eu.

We may use the following cookies:

• Strictly Necessary: We may use cookies that are necessary for the website to function and that enable you to navigate and use features. The strictly necessary cookie is Google Tag Manager.
• Analytic: We may use cookies to gather statistics in order to enhance the performance of the website. The analytic cookie is Google Analytics.
• Advertising: We may use cookies to provide more relevant messaging and marketing communications to you. The advertising cookie is Doubleclick.

You should also be aware that when you are on our website, you may be directed to other websites or content that belong to third parties which we have no relationship. We are not responsible for any third party website, content or services. You should review the privacy policy of each third party.

10. How to Contact Us

If you have any questions, requests or complaints related to how we process your personal data, please contact our Legal Department at legal@verlinvest.com or +32.2.626.98.70.

11. Updates

We may regularly review this Privacy Notice and may update it from time to time to reflect any changes to the way in which we treat personal data. We will post the updated Privacy Notice on our website.

This Privacy Notice was last updated on 5 December 2018.