Privacy Statement Aton Monday 08 September 2019 Aton values the protection of your privacy and aims at processing your personal data in a transparent and discreet way and in accordance with Directive 95/46/EC (GDPR). This Statement explains how and why Aton Solar BV (company number BE0731.601.912) and its associated companies (hereinafter jointly referred to as ‘Aton’) process your personal data within the meaning of the Belgian Companies Code. 1. What is personal data? Personal data is any information relating to identified or identifiable natural persons. 2. Which type of data do we collect? Personal data is collected only if you have decided to provide it to us. The information is used for performing the services offered by Aton. Personal data is not used for any other purpose, unless you give us permission to do so or Aton is required to do so by law. The personal data collected by Aton may include: name, address, date of birth, gender, email address, phone number, home address, family situation (marital status, dependants), financial Information and other similar information. 3. The legal bases for processing personal data Aton will process personal data only on either of the following legal bases: • Performance of the contract: the personal data that is processed is necessary for performing the services contractually agreed between you and Aton. • Legal obligations: the personal data must be processed so that Aton can meet certain legal obligations. • Legitimate interests: the personal data may be processed if that is in Aton’s legitimate interest for adequate and lawful performance of its business activities, provided that your interests do not override our legitimate interests. • The Data Subject’s consent: you have given your consent to the processing of your personal data. 4. Why do we collect your personal data? We collect personal data to ensure that we can provide the services requested by you and to improve our services. Your personal data is also used for direct marketing activities if you have indicated that you wish to be informed thereof. The data processing method may vary depending on the service provided to you by Aton. Furthermore, your personal data may be used to meet legal requirements and for administrative purposes (accounting, invoicing). 5. Website Terms and Conditions of Use Please refer to the disclaimer, legal information and terms and conditions of use for more information about our terms of use and data collection through our website. 6. With whom do we share your personal data? Your data will be used only within Aton. Apart from the exceptions listed below, your data will not be shared with third parties. • Your data may be shared with third parties if you have given us explicit consent to do so. • Your personal data will be shared with third parties – for instance service providers – if that is necessary for performing our activities. Aton only does business with renowned partners. • Your data may be shared with third parties if Aton is legally required to do so, for instance by the Tax Administration. • Your data may be shared with other members of the Aton network if that is necessary for administrative purposes or to fulfil professional services to clients. • In the event of a reorganisation within the company or the sale of any Aton entity to another organisation, Aton may disclose personal data related to the sale or other transfer of the company to which the data relates. Under no circumstances will your data be shared with third parties for commercial purposes. 7. How do we secure your data? To secure your personal data, Aton takes all reasonable and appropriate technical and administrative safety measures. This prevents unauthorised access, accidental destruction and modification of data as well as data breach to the largest extent possible. We constantly improve our systems to ensure that we can guarantee data security. Nevertheless, no system or procedure can offer absolute protection against the aforementioned risks. By providing your personal data to Aton you acknowledge and accept this. 8. How long do we keep your personal information? Aton keeps your data no longer than is necessary for performing its services, unless we are required to keep them for an extended period to comply with legal obligations. 9. What are your rights? 9.1. Right to access You have the right to obtain confirmation that we are processing your personal data and you have the right to access that data. Prior to giving you access to the data Aton may ask you for proof of your identity. 9.2. Right to rectification You have the right to rectification, free of charge, of any data concerning yourself that is incorrect or incomplete. 9.3. Right of erasure You have the right to request the erasure of your personal data. If we erase your personal data, certain services offered by Aton can no longer be provided. 9.4. Right to restrict processing You have the right to block or restrict the processing of your personal data. If processing is restricted, Aton may store the data, but no longer process it further. 9.5. Right to object You have the right to object to the processing of your personal data in three specific cases: • processing of data based on legitimate interests, the performance of a task carried out in the public interest or in the exercise of official authority; • direct marketing; • processing of data for scientific or historical research and statistical purposes. 9.6. Right to data portability You have the right to receive your personal information in a structured, commonly used and machine-readable format. Furthermore, you have the right to transmit the data in that format to another controller. 9.7. The right to file a complaint Aton aims at processing your data in the most transparent and correct way possible. If you should have the feeling that something is not right nonetheless, you can always contact our Data Protection Officer at the email address DPO@moorestephens.be. In addition, you have the right to file a complaint with the Belgian Data Protection Authority at 35 Rue de la Presse 1000 Brussels Phone: +32 (0)2 274 48 00 Fax: +32 (0)2 274 48 35 contact@apd-gba.be 10. Changes to this Statement Aton will evaluate this Statement from time to time and change it as necessary. The date of any changes will be indicated on the dedicated website page. We invite you to check our Privacy Statement regularly. Any substantial changes will be notified through the website. 11. Questions? If you have any questions about this Privacy Statement, please don’t hesitate to contact anh@atonsolar.be.