Privacy Policy

Introduction

This Privacy Notice explains:

(i) what personal data we (Valtech LLC and other related companies, collectively referred to as ‘Valtech’ or ‘we’) process about you,

(ii) how we process it and for what purpose. The Policy also provides:

(iii) information about your rights regarding the processing of your personal data,

(iv) an overview of the main activities we carry out with regard to your personal data that may be processed by Valtech.

This Privacy Policy may be amended from time to time to reflect changes in applicable law or in the way we process your personal data.

The General Data Protection Regulation (‘GDPR’) is considered the leading global standard in privacy regulation. Valtech has decided to comply with the GDPR standard in all countries where it does business, with possible additional measures depending on applicable local laws, such as the Personal Data Protection Act of Ukraine 2010, the UK Data Protection Act 2018 (‘UK DPA’), the California Consumer Privacy Act 2018 as amended by the California Privacy Rights Act 2020 (the ‘CCPA’), as well as the Canadian Privacy Act and the Quebec Act respecting the protection of personal data in the private sector (the latter two referred to as the ‘Canadian Laws’ and collectively as the ‘Other Applicable Laws’).

Information about Valtech LLC

Valtech LLC is part of the Valtech group, registered in Ukraine, with its head office at 10 Verkhniy Val Street, Kyiv, EDRPOU code 41230716. Any contacts or messages should be sent to the address specified in the ‘Contact Us’ section below.

A list of our legal entities can be found at https://www.valtech.com/list-of-valtech-operational-entities/, each of which may be a ‘Controller’ under the GDPR if it processes your personal data.

Where your personal data may come from

We may collect or receive your personal data:

· When you interact with Valtech websites.

· As part of email/other digital correspondence or subscriptions.

· During telephone calls or other verbal communications.

· Through paper communications.

· When you visit our offices.

· When you request or purchase products or services from us.

· When you provide products or services to us.

· As part of trade or other events, such as conferences or exhibitions.

· From third parties or business partners from whom we purchase, license or otherwise obtain data.

· Through social media.

· From publicly available sources, online or offline.

· During Know Your Customer and/or sanctions checks.

· From contractors, shareholders, affiliates, subsidiaries and newly acquired businesses, board members, government authorities, previous employers, educational institutions and member organisations.

Providing personal data may be necessary to access official documents, participate in events, or enter into contracts. Refusal to provide personal data may result in the inability to access services, information, or events.

What personal data we may collect

We may collect and process the following categories of personal data about you:

· Contact information, such as first name, last name, email address, telephone number and other contact information.

· Professional information, such as job title and/or level of experience, company name, industry, country of location, information related to employment, services or other relationships we may have with you, business contact details, banking and financial details, communication and correspondence information.

· Technical data, i.e. information obtained when you visit our website or interact with us on social media (including, but not limited to, IP addresses, email/website interactions, social media handles or usernames).

· Your opinions and views when you leave feedback about our business or services, or when you participate in forums or other events.

· Audio and video recordings or photographs when you participate in recorded meetings, events or forums.

· Details relating to sanctions or Know Your Customer checks.

We do not typically ask you for sensitive information (such as data relating to racial or ethnic origin, religious beliefs, criminal convictions, physical or mental health, or sexual orientation), and you are prohibited from posting or submitting such data, except where:

· such sensitive information is required by local law, or

· from time to time, in certain circumstances, to comply with dietary or accessibility requirements when attending events, forums or meetings.

How we may use your personal data

In accordance with the GDPR and other applicable laws, we may process your personal data:

· Because you have consented to the processing of your personal data.

· To perform a contract to which you or your employer is a party, or to take steps at your request prior to entering into a contract.

· To comply with legal obligations to which we are subject.

· When processing is necessary for the purposes of legitimate interests pursued by us or a third party (e.g. partners, service providers), except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data, except where the law of the country does not recognise legitimate interest as a legal basis.

Our legitimate interests include, but are not limited to, the administration, development and promotion of our business.

Please note that Valtech does not sell personal information.

Why we may need your personal data

Depending on how you interact with us, we may process your personal data in connection with our services or for other business purposes:

· Managing our relationship and administering our business with you or your organisation.

· Administering any accounts or profiles associated with you or your organisation, which may include registration, subscription, purchases, billing and/or payments.

· Responding to your questions and requests or carrying out your instructions, as well as fulfilling other specific purposes for which you have given your consent.

· Providing you with access to certain restricted parts of our websites.

· Enabling you to download certain documentation (e.g., technical documents).

· Enabling you to attend live or organised events or webinars.

· Allowing us to manage our website or service and ensure its security, including collecting aggregate statistics on website usage.

· For marketing or research purposes, as well as to develop new content, services and/or products aimed at improving, testing and expanding the capabilities of current services.

· Sending you offers and promotional materials or communications about our services that we believe may be of interest to you.

· Audience selection using third-party social networks (e.g. LinkedIn, Facebook and Instagram) to share our content with you through them.

· Providing you with personalised advertising.

· Managing forums in which you may participate.

· Conducting satisfaction surveys and collecting feedback about our services.

· Complying with legislation and legal obligations.

· Responses to requests or orders from courts, regulators or authorities when required by law.

· Exercising our rights and protecting our rights and/or property, as well as the rights and/or property of others.

How we may transfer or disclose your personal data

Your data may be transferred to the following categories of recipients:

· Other Valtech group entities (see https://www.valtech.com/list-of-valtech-operational-entities/).

· Business partners (e.g. to provide, sell or improve products/services or to organise events).

· Service providers (e.g. to forward your requests to them or to ensure data security and storage).

· Social networks or other marketplaces/advertising providers.

· Any organisations seeking to invest in or acquire our business.

· Third parties, if we believe that such disclosure is reasonably necessary to comply with applicable laws or regulations, or if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is lawful, necessary, or appropriate.

International data transfers

Valtech LLC is part of a global organisation with separate legal entities in many parts of the world and relies on an international infrastructure that typically results in global data flows. These flows may include countries around the world where we have offices, access or hosting systems, or where we conduct business, including countries outside the European Economic Area.

Accordingly, we may share your personal data with other Valtech group entities, for which we have appropriate legal documentation in place, including security safeguards.

In each specific case, we may also transfer your personal data to third parties. When relying on such third parties located outside the European Economic Area, we ensure that we have appropriate safeguards in place, such as:

· EU Standard Contractual Clauses.

· UK International Data Transfer Agreement or addendum to the EU Standard Contractual Clauses.

· Ensure that the third party is certified under the Data Transfer Framework Agreement and/or

· Similar provisions that may be required under other applicable laws.

Personal data security

The security of your personal data is our priority. Taking into account the nature, scope, context and purposes of each data processing operation, as well as the risks of varying likelihood and severity for your rights and freedoms, we implement all appropriate technical and organisational measures and policies to ensure the protection of your personal data and to prevent any accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to personal data transmitted, stored or otherwise processed by Valtech.

Your rights regarding your personal data

Data privacy laws around the world may give you rights regarding your personal data. These rights may vary depending on your location and applicable law. However, they generally include the following:

· The right of access, which allows you to access and obtain a copy of the personal data we hold about you.

· The right to rectification, which allows you to correct the information we hold about you.

· The right to request the deletion of your personal data.

· The right to restrict or object to the processing of your personal data in certain circumstances.

· The right to data portability, which allows you to receive and reuse your personal data for your own purposes across different services where possible.

· The right to restrict disclosure, request de-indexing, opt out of sales or cross-contextual behavioural advertising.

· The right to withdraw your consent at any time when the processing of your personal data is based on your consent, in particular by clicking on the unsubscribe link contained in the communications sent by Valtech and generated in response to your registration on Valtech websites.

You may exercise these rights at any time by writing to the relevant local data protection manager of the Valtech group of companies and/or data protection officer, as specified in the ‘Contact Us’ section below.

In accordance with applicable data protection laws, if you have any concerns about our use of your personal data, you also have the right to lodge a complaint with a supervisory authority. However, we ask that you contact us first so that we can discuss and find a quick solution to any potential issues you may have with Valtech's privacy and data protection policy.

Storage of personal data

We store your personal data for as long as is strictly necessary to fulfil the purposes for which it was collected, in accordance with applicable data protection legislation or the time limits recommended by supervisory authorities, and/or to comply with our legal or contractual obligations.

The criteria we use to determine data retention periods include:

· Your most recent interaction with us, particularly regarding marketing.

· Whether personal data is relevant and useful for providing our services.

· To meet financial or auditing requirements, statute of limitations laws, and relevant regulations or standards.

· In accordance with country or industry laws.

When the above criteria are met, your personal information will be permanently deleted, except in cases where personal data is archived for research purposes or for the sole purpose of providing it to judicial authorities. In addition, we may anonymise your data for statistical research purposes.

Changes to our Privacy Policy

We may change or supplement this Privacy Notice from time to time at our discretion. When we make changes to this Policy, we will change the revision date at the top of this page. We encourage you to refer to this Privacy Policy frequently to stay informed about our personal data practices.

Protecting Children's Privacy

We understand the importance of protecting children's privacy in the interactive online world. This Website is not intended for children under the age of 16 or knowingly targeted at children under the age of 16. Our policy is not to knowingly collect or maintain information from individuals who are under 16 years of age. Therefore, if you are under 16, please do not attempt to register for the Services or send us any personal data about yourself.

Contact us

Any questions, comments or concerns you may have regarding Valtech LLC's practices and compliance with local data privacy laws, our Privacy Notice or Valtech's online presence may be directed to our Data Protection Officer, Dmytro Kozlovsky, in writing at Valtech LLC, 10 Verkhniy Val Street, Kyiv, or at UA.privacy@valtech.com.