STRADA PARTNERS PRIVACY & COOKIES STATEMENT

The protection of your privacy is of the utmost importance to Strada Partners. We undertake to protect and process your personal data with transparency and fairness to you and in strict compliance with the applicable law, including the EU General Data Protection Regulation 2016/679 (“GDPR”), and The Belgian Electronic Communications Act (implementation of the Telecommunications Act) which is derived from the European e-Privacy Directive. This directive implies that each EU member state has a certain discretion with regard to cookie legislation.

Our data processing activities are conducted: 1) with your consent; 2) in order to fulfil our obligations to you; 3) for the legitimate purposes of operating our business, or 4) otherwise in accordance with the law.

The purpose of this privacy and cookies statement is to adequately inform you and to explain how we collect, use and store your personal data. You may object to the processing of your data, as explained in Chapter 6 of this notice.

1. Scope of this privacy and cookies statement

A. Context and Who is Who?

We are Marklaan Advisory BV, a company incorporated under Belgian law, having its registered office at Frankrijklei 106, 2000 Antwerp, Belgium (“Strada Partners", “we”) and registered with the Crossroads Bank for Enterprises under enterprise number 0779.326.506.

"Processing" means any operation or set of operations which is performed upon personal data such as collection, recording, organization, storage, adaptation, alteration, retrieval, consultation, use, disclosure by means of transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction of personal data.

The “controller” as defined by the GDPR means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data as described above. Strada Partners will be the controller with regard to the processing of your personal data.

“Cookies” mean small data or text files which are placed and stored on your local computer if you visit our website. Cookies help Strada Partners to do different things, such as enabling certain features on our website or measure how visitors such as you use our website. Our objective with the use of cookies is to enable you to use our website conveniently and to provide you with the best possible service during your site visits. They enable us to optimize our website.

B. Audience of this privacy and cookies statement

Those affected by this privacy and cookies statement are:

Website visitors or persons who contact us by e-mail or otherwise, who are identified or identifiable natural persons;
All other identified or identifiable natural persons who are involved in any transaction with Strada Partners as representatives of our customers, subcontractors, prospects, candidates etc. whether private individuals or legal entities (for example company directors, agents, legal representatives or other contact persons).

C. Extent of data

The data covered by this privacy and cookies statement are personal data, i.e. any information in relation to an identified or identifiable natural person. We may collect personal data from you directly, or from other sources, such as:

identification data: your name, e-mail address, IP address;
data relating to your behavior and habits when using our website.

Such personal data will be collected:

from data you enter yourself;
from data we receive from other parties;
from data through your use of our website (such as IP address, device ID etc);
through the cookies.

The following personal data will have to be provided on a mandatory basis:

- Technical information such as IP-address

The following personal data will have to be provided on a voluntary basis:

- Data collected through the cookies

D. Types of cookies

Cookies can be divided into categories according to their origin, function and lifetime.

1. Origin:

First-party cookies (direct cookies): these cookies are set by Strada Partners during your visit to our site.
Third-party cookies (indirect cookies): these cookies are set by a third party when you visit the Strada Partners website, such as cookies set by Google, Twitter or Facebook. With regard to cookies set by third parties we refer you to the statements on their own websites. Please note that Strada Partners has no influence whatsoever either on the contents of these statements or on the actual contents of the cookies set by these parties.

2. Function:

Strictly necessary cookies: these cookies are required in order to browse our website.
Functional cookies: these cookies allow our website to remember your preferences. They include login cookies, registration cookies and language preference cookies. Functional cookies are first-party cookies.
Performance cookies: these cookies are set on the website for statistical, social or commercial purposes or to generate general visitor profiles. The purpose of performance cookies is basically to make your browsing session easier, more convenient and more enjoyable. Performance cookies may be first-party or third-party.
- Cookies set for statistics purposes enable the site managers to see which website pages you have visited and to geographically locate the computer/device used, e.g. Google Analytics.
- Cookies set for social purposes enable users to share website content on the social networks: Twitter, Facebook, etc. if they wish.
Marketing cookies: these cookies are placed on the website for marketing purposes.
- Cookies set for profiling purposes enable the site managers to establish user profiles so as to be able to display advertising suited to their main interests: e.g. DoubleClick cookies.
- Cookies set for advertising purposes record the advertisements that have been displayed during a user’s browsing sessions and their frequency. A number of cookies of this kind are used by Google Analytics. Convenience cookies may be either first-party or third-party cookies.

3. Lifetime:

Persistent cookies: also known as 'tracking cookies', these outlast an individual session and remain on your hard disk for a predefined period of time or until you choose to delete them.
Session cookies: these are temporary cookies that enable visitors to navigate quickly and easily through the site during a browsing session. A browsing session begins when the visitor opens the browser window and ends when the visitor closes the window. All session cookies are deleted when you close your browser. Session cookies are usually functional cookies.

2. Purposes

A. Data processing

Your personal data may be processed for any of the following purposes:

1) To improve our websites and our services;

2) To fulfil legal and contractual obligations;

3) To market our services (including sending you promotional messages about our products and services);

4) To maintain our business relationship, where you are a user of our website, a client or a candidate;

5) To comply with legal, regulatory and judicial requirements and reasonable requests; and

6) To defend ourselves in the event of a legal claim.

In accordance with the GDPR, we process your personal data based on the following legal grounds:

We base the processing of personal data for (2) and (4), on the necessity for the performance of a contract or pre-contractual obligations we have concluded with the data subject (art. 6.1 b) GDPR).
We base the processing of personal data for (5) and (6) on the necessity for compliance with a legal obligation (art. 6.1 c) GDPR).
We base the processing of personal data for (1) and (3) on the explicit consent from the data subject (art. 9.2 a) GDPR).

B. Cookies

Cookies are essential for us to optimize every visit to the website. For example, cookies remember every technical choice the user has made (e.g. choices regarding language, newsletter, etc.) and help to offer the user all relevant services and suggestions.

Strada Partners uses session, preference, security and tracking cookies. Session cookies are used to operate our Service. Preference cookies are used to remember your preferences and various settings. Security cookies are used for security purposes and analytical cookies are used for the compilation of statistics on the number of visitors, our most popular webpages, etc.

Name of the cookie

Purpose of the cookie

Personal data being processed

First or third party cookie

Retention period, if applicable

Google Analytics

Scanning the website for cookies and mapping out all the tracking present and operating on the website

Tracking and profiling on account of personal information, such as IP addresses, unique IDs and Client IDs

Third party cookie

Remembers the specific user choices for a year and controls the cookies accordingly

To visit our website, it is recommended to enable cookies on your computer, tablet or mobile phone. If you prefer not to, you can disable cookies by changing browser settings.

3. Sharing your personal data

We may disclose your personal data to the following parties:

With our service providers and partners: We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations. We also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners

With law enforcement/when required by law: We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

When transferring personal data to third parties, we always ensure that we implement appropriate technical and organizational protection measures. Where necessary, we will, for example, conclude a transfer agreement or a processor agreement, which sets out restrictions on the use of your personal data and obligations in respect of the security of your personal data.

Your personal data will not be lent or sold to third parties for marketing purposes without your prior express consent.

To the extent that your data is transferred in the context of this article to countries outside the European Union which do not provide an adequate level of protection for your data, Strada Partners will ensure that the companies to which your data is transferred do provide an adequate level of protection. In particular, we have concluded Standard Contractual Clauses (SCC) with them. Strada Partners guarantees to always verify, on a case-by-case basis, whether an adequate level of protection is in place for transfers to third countries.

4. Protection of your data

We have set up technical and organizational adequate standards of security in our own operations when it comes to safeguarding and protecting personal data in accordance with our legal obligations. By doing so, we want to prevent any unauthorized person from gaining access to, processing, altering or deleting personal data and to protect your personal data as best as we can against the destruction and loss. More information on our security measures is available upon request.

5. Retention of your data

We will not keep your personal data for longer than necessary for the processing purposes for which your data were collected (as described above). We will appropriately and securely dispose of your personal data when we no longer need them. We take into account the sensitivity of your personal data, the purpose and the legal requirements in order to use the appropriate retention period.

We keep basic information about our customers and suppliers for up to 10 years for liability, legal, tax and compliance purposes after the end of a contract. In specific cases, we may be required to retain these data for a longer period of time, for example in the event of a legal dispute, if is (i) necessary to cover our liability or (ii) required or permitted by law. All personal data purely for the purpose of scientific research or statistical purposes may be stored for longer periods.

6. Your rights

We will use reasonable efforts to ensure that your personal data is accurate and up to date. Therefore, please advise us of any changes to your information.

In accordance with the GDPR, you are entitled to request access to the details of personal data we hold about you and to have it rectified or even erased, in certain specific cases. You may also object to the processing of your personal data if the processing is carried out on the legal basis of a legitimate interest. You also have the right to object to the processing of your personal data for direct marketing purposes. This right is absolute – we will always comply with it. Furthermore you have the right to restriction of the processing of your personal data in certain specific cases. If the processing of personal data is based on your explicit consent, you may withdraw your consent at any time without affecting the lawfulness of processing such data prior to such withdrawal.

You have the right to access the personal data you have provided us, in a structured, commonly used and machine-readable format and you have the right to transmit this data to another controller without consent from us (data portability). This right is however subject to restrictions and conditions.

In relation to exercising your rights, you can send us your signed and dated request. Please be as accurate as possible when formulating requests:

By regular mail to:

Marklaan Advisory BV

Attn. Legal Department

Frankrijklei 106

2000 Antwerp

Belgium

By e-mail to our Operations & Compliance Manager, Ms. Phaedra Beyers: phaedra.beyers@strada-partners.com.

We will respond to your request as soon as possible and in any event within four (4) weeks after receipt of your request. The exercise of these rights is in principle free of charge. Only in case of unreasonable or repeated requests may we charge a reasonable administrative fee. It is possible that we will first ask you for proof of identity in order to verify your identity.

In case of disagreement relating to the processing of your personal data, you have the right to contact the competent data protection authority. However, we encourage you to contact us first in order to try to seek a pragmatic and amicable solution regarding the disagreement.

The contact details of the Belgian Data Protection Authority are as follows:

Data Protection Authority

Rue de la Presse/Drukpersstraat 35

B-1000 Brussels

Belgium
Tel.: +32 2 274 48 00

E-mail: contact@apd-gba.be

www.gegevensbeschermingsautoriteit.be

7. References to other websites

Our website may contain links to other sites that are not operated by us. If you click on a third-party link, you will be redirected to that third-party site. We strongly recommend that you review the Privacy Policy of each site you visit.

We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites or services

8. Changes to this privacy and cookies statement

This privacy and cookies statement may be amended from time to time. We invite you to review the latest version of this privacy and cookies statement online.

This policy was last reviewed on 20 January 2023.

9. Contact details

If you have any queries about this privacy and cookies statement, please contact Strada Partners: