Privacy Policy

Version No. 1.

Date: May 9, 2018.

We have prepared this document to explain the circumstances under which we process your personal data and how we protect it. We may update thisPrivacy Notice from time to time. We will publish any changes made to this document on our website so that you always know what information we collect, how we may use it, and in which cases we may share this data with third parties. Therefore, we ask that you review this document regularly.

ThisPrivacy Noticeprimarilyconcernsthe processing of personal data of our current customers and, in some cases, our former customers, our suppliers, our prospects, as well as their employees and the individuals they designate, individuals who express an interest in our activities, and individuals with whom we come into contact in the course of conducting our business.

In accordance with data protection laws, we would like to inform you of the following:

1)ThisPrivacy Noticeapplies to the processing activities carried out by the following companies within the SERIS Nederland group:

SERIS Holding B.V., Kerkeplaat 2G, 3313 LC Dordrecht, Chamber of Commerce number 24251292

SERIS Security B.V., Kerkeplaat 2G, 3313 LC Dordrecht, Chamber of Commerce number 52242072, ND license ND21;

SERIS Facility B.V., Kerkeplaat 2G, 3313 LC Dordrecht, Chamber of Commerce number 24251293

SERIS Safety B.V., Kerkeplaat 2G, 3313 LC Dordrecht, Chamber of Commerce number 52241831

Hereinafter collectivelyreferred to as “SERIS”.

 2)The email address forSERIS’s Data Protection Officersis:dpo@seris.nl.

 3)The personal data we may process are as follows:

Identification details: last name, first name, language, title, position, type and numbers of identification documents, etc.

Contact information: mailing address, landline and/or cell phone number, email address, etc.

Financial information: bank account number.

Other special categories of personal data required by the Private Security Organizations and Investigation Agencies Act (Wpbr).[2]

Information regarding the recording of images: surveillance footage.

Information regarding audio recordings: telephone calls made via landlines.

4)If you have a contractual relationship with SERIS, this agreement serves as the basis for the processing of personal data. The purpose of processing personal data is to enable SERIS to ensure the performance of the services specified in the contract, as well as the general management of customers and suppliers, including accounting, the management of disputes and legal proceedings, the collection or transfer of debts, and the protection of our rights.

We process your personal data based on our legitimate interest, which allows us to offer you promotions related to similar products or services that you have used, to keep you informed about our activities and those of our industry, and to protect our operations, property, and buildings by recording visitor information.

We process your personal data based on your consent when you subscribe to our newsletter, when you send us a request for information, when you call us (in which case you will be informed in advance that the call may be recorded), or when you enter our premises where a CCTV sign is displayed. You can unsubscribe from the newsletter at any time.

Finally, the processing of your personal data may be justified to comply with our legal obligations. In this regard, we are subject to tax and accounting obligations that require us to retain certain personal data and disclose it to the tax and accounting authorities.  Furthermore, we are subject to legal obligations pertaining to our sector, which is strictly regulated and requires us to disclose certain information to our supervisory authority upon their explicit request or on our own initiative.

5) SERISretains your personal data until your relationship with SERIS ends (for example, if you are no longer bound by a contract with SERIS or if you unsubscribe from the SERIS newsletter). There are exceptions to this principle in the following cases:

(a) if there is a statutory retention period;

(b) to comply with any applicable statute of limitations;

c) to defend and enforce our or your rights in the event of a dispute or disagreement.

6)Your personal data will be accessible to individuals designated in accordance with the “need-to-know” principle, in order to achieve the purposes listed above.

A company within the SERIS Group may disclose your personal data to another company listed in point 1) above if this is necessary to comply with a legal or contractual obligation.

SERIS will not disclose your personal data to third parties without prior notice, unless such disclosure is required due to legal or contractual obligations, or judicial or police measures.

When SERIS engages external subcontractors, they are always contractually obligated to process your personal data in accordance with applicable regulations as part of the performance of the agreement, and not to process your personal data for any purposes other than those specified in our standard subcontracting agreement. For example, if a customer opts for this service, SERIS Security may, at the customer’s request, grant the customer access to an ERP solution, enabling monitoring and reporting on the security activities carried out by SERIS Security at the customer’s request. This platform is hosted by an external subcontractor of SERIS, to whom the customer’s personal data is transferred. This transfer is limited to the information necessary to enable this external subcontractor to perform the task we have contractually entrusted to them.

7)In accordance with the General Data Protection Regulation[1], everyone has the following rights under certain conditions:

1) access to and correction of personal data;

2) deletion of personal data in the cases specified by law;

3) in the event of a dispute regarding the processing of personal data, the restriction of the processing of such personal data until the dispute is resolved;

4) the portability of personal data;

5) to object at any time and without providing a reason to the processing of personal data for direct marketing purposes or automated individual decision-making.

If the processing of your personal data is based on your consent, you have the right to withdraw it at any time.

Anyone wishing to exercise these rights is asked to send an email todpo@seris.nl. You also have the right to file a complaint with the Dutch Data Protection Authority viahttps://www.autoriteitpersoonsgegevens.nl/

8)SERIS continuously monitors the security of personal data within the company. SERIS undertakes to take all reasonable technical and organizational measures to prevent unauthorized persons from accessing the personal data entrusted to SERIS, and to prevent any unauthorized loss, destruction, or disclosure of personal data. SERIS uses systems that are regularly updated, allowing personal data to be encrypted when necessary, and the firewalls comply with industry standards.

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[1]Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data (…),Official Journal of the European Union, May 4, 2016, L 119/1.

[2]In accordance with the Private Security Organizations and Investigation Agencies Act (Wpbr), effective from July 4, 2013, to the present.