Haven Ventures Ltd and its affiliates (together: “Haven Ventures” or “we”) have created this privacy statement to demonstrate our commitment to the individual’s right to data protection and privacy.

This privacy statement applies to the processing of personal data in the context of our global business operations. This includes the processing of personal data through our website www.havenventures.com. This privacy statement contains information on the categories of personal data we collect, why we collect it, what we do with it, how we protect it and your individual rights.

Haven Ventures is the so-called controller in the sense of the General Data Protection Regulation (‘GDPR’). This privacy statement explains in general terms how we seek to comply with data protection laws and regulations, including but not limited to the European General Data Protection Regulation (“GDPR”) and national laws implementing the GDPR, as well as state security breach laws and data protection laws in the United States, and applicable data protection legislation in other jurisdictions, such as Australia.

If, after reading our privacy statement, or in a more general sense, you have any questions or wish to contact us, you can do so via the contact details at the end of this document.

We process personal data of (contact persons at) our customers, suppliers and other relations, students and job applicants, and of visitors of our websites. We obtain r personal data i) from you, ii) from third parties (such as customers, suppliers and chain partners), or iii) from public sources, for example, the Trade Register of the Chamber of Commerce.

Personal data that we may process are:

• basic information such as your first and last name, title, gender;
• contact details such as your e-mail address, postal address, telephone number, the company you work for and your position;
• financial information, such as IBAN/bank account number;
• IP address and statistical data about your use of our websites;
• personal data you provide us with when applying for a job with us, such as an application letter, CV, date of birth, education and career information; any other personal data we obtain from or about you that we use for the purposes mentioned below.

We do not always process all the above data, this depends on the type of relationship, the service in question and (if applicable) the consent you have given us.

We process your personal data for one or more of the following purposes (depending on our relationship with you):

purposes We use your personal data to send out newsletters, invitations to our events and other marketing communications that may be relevant to you, as well as in the context of a (registration for) one of our marketing events. When you have attended one of our events, we may also contact you for feedback.

We process your personal data as necessary within the context of the products or services provided by us, including the exchange of personal data for quotations, the execution and completion (including invoicing) of an order, service request or assignment.

We process your personal data as necessary to comply with legal obligations. For example, the collection and storage of data and the provision of information to the tax authorities and supervisory authorities.

The data you share with us if you apply for a job with us (via email/mail, the job application form on our website or via social media) or that we receive via recruiters, is processed by us to contact you for the purposes of our job application procedures and to deal with your job application. We may also process your personal data in the context of (registration for) an internship at one of our branches.

For safety purposes (evacuation in case of calamities) we keep a list of visitors to our business premise(s). These lists are destroyed at the end of the day in question. We also use camera surveillance to protect the possessions and safety of our employees and visitors. For more information regarding camera surveillance, we refer to our CCTV policy, which is available at the front desk of each site, and which applies to all Haven Ventures sites.

We process statistical data about your visit and use of our website. We do this to analyze and improve the content, layout, and use of our website.

We may also process your data to carry out customer satisfaction surveys, or to handle any questions or complaints.

We process your personal data based on one or multiple of the following legal grounds:

• The performance of an agreement with you or to take measures before the conclusion of an agreement;
• A legitimate interest;
• Your consent;
• Our compliance with legal obligations;

In some cases, we may share your Personal Data with third parties. We will only do this when considered necessary. We only share your data with trustworthy parties and ensure that a transfer of your personal data is subject to appropriate safeguards. We may share your personal data with:

• Government institutions such as the tax authorities and supervisory authorities;
• Haven Ventures affiliates, customers, suppliers and subcontractors;
• Chain partners and other service providers such as banks, insurers, bailiffs, accountants, tax advisers and other advisers;
• External suppliers such as IT service providers, hosting and cloud service providers or other suppliers to which we outsource support services;

If the third party with which your personal data is shared is designated a processor in the sense of the GDPR, we will also conclude a data processing agreement with this third party.

We will retain your personal data in accordance with applicable data protection legislation and specific mandatory retention periods. The data will not be retained for longer than necessary to achieve the purpose for which it was collected and to comply with legal obligations.

Under the GDPR, you have the following rights:

You have the right to request us to access, rectify, erase, restrict and transfer your personal data. You also have the right to object to the processing of your personal data. If you wish to exercise your rights, please submit a request via e-mail. Our contact details can be found at the end of this privacy statement. Please note that individuals’ rights under the GDPR are subject to certain restrictions and may not always be granted. A request may be denied in part or in full following these restrictions, such as legal obligations, the rights of third parties and the legitimate interests of Haven Ventures. If we are unable to grant a particular request, we will inform you of this, with a statement of reasons.

As far as the processing of your personal data is based on consent, you have the right to revoke this consent at any time. Any withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal.

Within the EU, EU citizens have the right to lodge a complaint with a supervisory data protection authority. A list of all EU supervisory authorities is available on the European Data Protection Board website: https://edpb.europa.eu/about-edpb/board/members_en. In the Netherlands this is the ‘Autoriteit Persoonsgegevens’ (‘AP’). More information can be found on the website of the AP (https://autoriteitpersoonsgegevens.nl/). We would appreciate it if you would contact us first so that we try to reach an amicable solution.

We take appropriate security measures to limit abuse of and unauthorized access to personal data. For example, we ensure that only authorized persons have access to the data, that access to and transfer of the data is protected by appropriate safeguards such as secured connections and firewalls and that our security measures are evaluated and updated regularly.

All information you provide to us via our websites will be stored on servers in the European Economic Area (EEA). If necessary, we may share information with our affiliated companies in and outside the EEA.

If we share and or store personal information outside the EEA, appropriate safeguards will be put in place.

We use cookies to personalize content and ads, to provide social media features and to analyze our traffic. We also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you have provided to them or that they have collected from your use of their services.

Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. You can also individualize cookie settings on our websites through the pop-up notice. If you choose to decline certain cookies, it could be that you may not be able to access all or parts of our websites.

We do not knowingly collect personally identifiable information from children. If you become aware that a child has provided us with personal data, please contact us.

We may change this privacy statement from time to time. Changes will be published on our websites. It is therefore advisable to consult our websites regularly to keep up to date with any changes.

Haven Ventures welcomes your comments regarding this privacy statement. For any questions or requests regarding the processing of your personal data, please contact us through the contact details below.

email@havenventures.com

This privacy statement was last updated and posted on September 15th, 2023