Privacy Statement

As of July 2021

I. Name and Address of the Company Responsible

The company responsible within the meaning of the General Data Protection Regulation (GDPR) and other data protection regulations is:

NAS Invest AcquiCo 65 S.à r.l
33 rue du Puits Romain,
L-8070 Bertrange
Luxembourg

II. Contact Details of the Data Protection Officer

The data protection officer of the company responsible is:

Knittel Akademie für Datenschutz & Compliance
Mescheder Weg 57
D-13507 Berlin
Germany

(030) 55 22 81 66 (by appointment)

0172 317 82 47

knittel@knittel-compliance.de
www.knittel-compliance.de

III. General Information on Data Processing

1. Scope of the processing of personal data

We only process the personal data of our users insofar as this is necessary for the provision of a functional website as well as our contents and services. The processing of personal data is carried out regularly once the user has given their consent for us to do so. An exception applies only in those cases in which obtaining prior consent is not possible for factual reasons and the processing of the data is required by legal regulations.

2. Legal basis for the processing of personal data

Insofar as we obtain the consent of the relevant person for the data to be processed, Art. 6 Para. 1 p. 1 lit. a GDPR serves as the legal basis.

When processing personal data that is necessary for the performance of a contract to which the data subject is a party, the legal basis is Art. 6 Para. 1 p. 1 lit. b GDPR. This also applies to processing operations that are necessary for the performance of pre-contractual measures.

Insofar as the processing of personal data is necessary for the fulfilment of a legal obligation to which our company is subject, Art. 6 Para. 1 p. 1 lit. c GDPR serves as the legal basis.

In the event that vital interests of the data subject or another natural person make the processing of personal data necessary, Art. 6 Para. 1 p. 1 lit. d GDPR serves as the legal basis.

If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 Para. 1 p. 1 lit. f GDPR serves as the legal basis for the processing.

3. Data deletion and storage duration

The personal data of the data subject will be deleted or blocked as soon as the purpose of the storage no longer applies. Storage may also take place if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the person responsible is subject. Data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires unless there is a necessity for the continued storage of the data for the conclusion or fulfilment of a contract.

IV. Rights of the Data Subject

If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights against the controller:

1. Right of access

You may request confirmation from the controller as to whether personal data relating to you is being processed by them.

If such processing is taking place, you may request that the controller provides you with the following information:

• The purposes for which the personal data is processed;
• The categories of personal data which are processed;
• The recipients or categories of recipients to whom the personal data relating to you has been or will be disclosed;
• The planned duration of the storage of the personal data relating to you or, if specific information on this is not available, criteria for determining the storage duration;
• The existence of a right to rectify or erase personal data concerning you, a right to restrict processing by the controller, or a right to object to such processing;
• The existence of a right to appeal to a supervisory authority;
• Any available information on the origin of the data if the personal data is not collected from the data subject;
• The existence of automated decisions, including profiling, according to Art. 22 Para. 1 and 4 GDPR and, at least in these cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.

You have the right to request information on whether personal data concerning you is transferred to a third country or to an international organisation. In this context, you may request to be informed about the appropriate safeguards according to Art. 46 GDPR in connection with the transfer.

2. Right to rectification

You have a right to rectification and/or completion against the controller if the personal data being processed is inaccurate or incomplete. The controller shall carry out the rectification without undue delay.

3. Right to restriction of processing

You may request the restriction of the processing of your personal data under the following conditions:

• You contest the accuracy of your personal data for a period, enabling the controller to verify the accuracy of the data;
• The processing is unlawful and you refuse to erase the personal data and instead request the restriction of the use of the personal data;
• The controller no longer needs the personal data for the purposes of processing, but you need them for the assertion, exercise, or defence of legal claims, or
• If you have objected to the processing according to Art. 21 Para. 1 GDPR and it has not yet been determined whether the legitimate reasons of the controller outweigh your reasons.

Where the processing of your personal data has been restricted, such data may be processed, with the exception of storage, only with your consent or for the establishment, exercise, or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of substantial public interest of the union or member state.

If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

4. Right to deletion

a) Obligation to delete

You may request the controller to delete your personal data without undue delay and the controller is obliged to delete such data without delay if one of the following reasons applies:

• Your personal data is no longer necessary for the purposes for which it was collected or otherwise processed.
• You withdraw your consent on which the processing was based according to Art. 6 Para. 1 p. 1 lit. a or Art. 9 Para. 2 lit. a GDPR and there is no other legal basis for the processing.
• You object to the processing according to Art. 21 Para. 1 GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing according to Art. 21 Para. 2 GDPR.
• Your personal data has been processed unlawfully.
• The deletion of your personal data is necessary for compliance with a legal obligation under union or member state law to which the controller is subject.
• Your personal data has been collected in relation to information society services offered in accordance with Art. 8 Para. 1 GDPR.

b) Information to third parties

The right to deletion does not exist insofar as the processing is necessary:

• For the exercise of the right to freedom of expression and information.
• For compliance with a legal obligation which requires processing under union or member state law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• For reasons of public interest in the area of public health according to Art. 9 Para. 2 lit. h and i and Art. 9 Para. 3 GDPR;
• For archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes according to Art. 89 Para. 1 GDPR, insofar as the right referred to in Section a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing, or
• For the assertion, exercise or defence of legal claims.

c) Exceptions

The right to deletion does not exist insofar as the processing is necessary:

• For the exercise of the right to freedom of expression and information.
• For compliance with a legal obligation which requires processing under union or member state law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• For reasons of public interest in the area of public health according to Art. 9 Para. 2 lit. h and i and Art. 9 Para. 3 GDPR;
• For archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes according to Art. 89 Para. 1 GDPR, insofar as the right referred to in Section a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing, or
• For the assertion, exercise or defence of legal claims.

5. Right to information

If you have asserted the right to rectification, deletion, or restriction of processing against the controller, the controller is obliged to inform all recipients to whom your personal data has been disclosed of this rectification or deletion of the data, or restriction of processing unless this proves impossible or involves a disproportionate effort.

You have the right against the controller to be informed about these recipients.

6. Right to data portability

You have the right to receive your personal data which you have provided to the controller in a structured, commonly used and machine-readable format. You also have the right to transfer this data to another controller without hindrance from the controller to whom the personal data was provided, provided that:

• The processing is based on consent according to Art. 6 Para. 1 p. 1 lit. a GDPR or Art. 9 Para. 2 lit. a GDPR or on a contract according to Art. 6 Para. 1 p. 1 lit. b GDPR and
• The processing is carried out with the help of automated procedures.

In exercising this right, you also have the right to have your personal data transferred directly from one controller to another controller, insofar as this is technically feasible. This must not affect the freedoms and rights of other persons.

The right to data portability does not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7. Right to objection

You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data which is carried out on the basis of Art. 6 Para. 1 p. 1 lit. e and f GDPR; this also applies to profiling based on these provisions.

The controller shall no longer process your personal data unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or for the establishment, exercise, or defence of legal claims.

If your personal data is processed for the purpose of direct marketing, you have the right to object at any time to the processing of your personal data for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.

If you object to the processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

In connection with the use of information society services, notwithstanding Directive 2002/58/EC, you have the possibility to exercise your right to object by means of automated procedures using technical specifications.

8. Right to revoke the declaration of consent under data protection law

You have the right to revoke your declaration of consent under data protection law at any time. The revocation does not affect the lawfulness of the processing carried out on the basis of the consent up until the revocation.

9. Automated decisions in individual cases including profiling

You have the right not to be subject to a decision based solely on automated processing – including profiling – which produces legal effects concerning you or, similarly, affects you significantly. This does not apply if the decision

• is necessary for the conclusion or performance of a contract between you and the controller,
• is permissible under union or member state legislation to which the controller is subject and that legislation contains adequate measures to safeguard your rights and freedoms and you legitimate interests, or
• is made with your express consent.

However, these decisions may not be based on special categories of personal data according to Art. 9 Para. 1 GDPR, unless Art. 9 Para. 2 lit. a or b GDPR applies and appropriate measures have been taken to protect the rights and freedoms and your legitimate interests.

With regard to the cases referred to in 1. and 3. above, the controller shall take reasonable steps to safeguard the rights and freedoms as well as your legitimate interests, which include at least the right to obtain the intervention of a person on the part of the controller, to express their point of view and to contest the decision.

10. Right to complain to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the member state of your residence, place of work, or the place of the alleged infringement, if you consider that the processing of your personal data violates the GDPR.

The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Art. 78 GDPR.

V. Provision of the website and creation of log files

1. Description and scope of data processing

Each time our website is accessed, our system automatically collects data and information from the system of the accessing computer, the following data is collected:

• Information about the browser type and the version used
• The operating system of the user
• The IP address of the user
• Date and time of access

This data is stored in the log files of our system. This data is not stored together with other personal data of the user.

2. Purpose of data processing

The temporary storage of the IP address by the system is necessary to enable delivery of the website to the user's computer. For this purpose, the user's IP address must remain stored for the duration of the session.

The storage in log files is done to ensure the functionality of the website. We also use the data to optimise the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.

These purposes are also in our legitimate interest in data processing according to Art. 6 Para. 1 p. 1 lit. f GDPR.

3. Legal basis for data processing

The legal basis for the temporary storage of data and log files is Art.6 Para. 1 p. 1 lit. f GDPR.

4. Duration of storage

The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended.

In the case of the storage of data in log files, this is the case after seven days at the latest. Storage beyond this period is still possible. In this case, the IP addresses of users are deleted so that an assignment of the requesting client is no longer possible.

5. Possibility of objection and removal

The collection of data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. As a result, it is not at all possible for the user to object.

VI. Use of Cookies

1. Description and scope of data processing

Our website uses cookies. Cookies are text files which are stored in the internet browser or by the internet browser on the user's computer system. When a user enters a website, a cookie may be stored on the user's operating system. This cookie contains a character string that enables the browser to be uniquely identified when the website is entered again.

We use cookies to make our website more user-friendly. Some elements of our website require that the requesting browser can be identified even after a page change.

The following data is stored and transmitted in the cookies:

The user data collected in this way is pseudonymised by technical precautions. It is therefore no longer possible to assign the data to the user. The data is not stored together with any other personal data of the user.

2. Purpose of data processing

The purpose of using technically necessary cookies is to simplify the use of websites for users. Some website functions cannot be offered without the use of cookies. For these functions, it is necessary that the browser is recognised even after a page change.

We require cookies for the following applications:

• Backend Login CMS

The user data collected through technically necessary cookies is not used to create user profiles.

3. Legal basis for data processing

The legal basis for the processing of personal data using technically necessary cookies is Art. 6 Para. 1 p. 1 lit. f GDPR.

4. Duration of storage, possibility of objection and removal

Cookies are stored on the user's computer and transmitted to our site by the user. You as a user therefore have full control over the use of cookies. By changing the settings in your internet browser, you can deactivate or restrict the transmission of cookies. Cookies which have already been stored can be deleted at any time. If cookies are disabled for our website, it may no longer be possible to use all the functions of the website to their full extent.

If you are using a Safari browser from version 12.1, cookies will automatically be deleted after seven days. This also applies to opt-out cookies, which are set to prevent tracking measures.

VII. Email Contact

1. Description and scope of data processing

On our website, it is possible to contact us via the email address provided. In this case, the user's personal data which is transmitted with the email will be stored.

Data is used exclusively for processing the conversation.

2. Purpose of data processing

In the case of contact by email, this also constitutes the necessary legitimate interest in processing the data.

3. Legal basis for data processing

The legal basis for the processing of data transmitted in the course of sending an email is Art. 6 Para. 1 p. 1 lit. f GDPR. Should the email contact refer to the conclusion of a contract, the additional legal basis for the processing is Art. 6 Para. 1 p. 1 lit. b GDPR.

4. Duration of storage

The data shall be deleted as soon as it is no longer required to achieve the purpose for which it was collected. For personal data which has been sent by email, this is the case when the respective conversation with the user has ended. The conversation is ended when the circumstances indicate that the matter in question has been clarified in full.

The additional personal data collected during the sending process shall be deleted after a period of seven days at the latest.

5. Possibility of objection and removal

The user has the possibility to revoke their consent to the processing of personal data at any time. If the user contacts us by email, they may object to the storage of their personal data at any time. The conversation cannot be continued in such a case.

All personal data stored in the course of contacting us will be deleted in this case.

VIII. Contact Form

1. Description and scope of data processing

Our website contains a contact form which can be used to contact us electronically. Should a user take advantage of this option, the data entered in the input mask is transmitted to us and stored.

At the time the message is sent, the following data is stored:

• Email address
• Surname
• First name
• Date and time of contact
• Further details that you send us as a message

For the processing of the data, your consent is obtained during the sending process and reference is made to this privacy statement.

Alternatively, it is possible to contact us via the email address provided. In this case, the user's personal data which was transmitted with the email will be stored.

Data is used exclusively for processing the conversation.

2. Purpose of data processing

The processing of personal data from the input mask serves us solely to process the contact. In the case of contact via email, this also constitutes the necessary legitimate interest in processing the data.

The other personal data processed during the sending process serve to prevent the misuse of the contact form and to ensure the security of our information technology systems.

3. Legal basis for data processing

The legal basis for the processing of data, providing the user has given their consent, is Art. 6 Para. 1 p. 1 lit. a GDPR.

The legal basis for the processing of data transmitted in the course of sending an email is Art. 6 Para. 1 p. 1 lit. f GDPR. Should the email contact refer to the conclusion of a contract, the additional legal basis for the processing is Art. 6 Para. 1 p. 1 lit. b GDPR.

4. Duration of storage

The data shall be deleted as soon as it is no longer required to achieve the purpose for which it was collected. For personal data which has been entered into the contact form or sent by email, this is the case when the respective conversation with the user has ended. The conversation is ended when the circumstances indicate that the matter in question has been clarified in full.

5. Possibility of objection and removal

The user has the possibility to revoke their consent to the processing of personal data at any time. If the user contacts us by email, they may object to the storage of their personal data at any time. The conversation cannot be continued in such a case.

All personal data stored in the course of contacting us will be deleted in this case.

IX. Hosting

The website is hosted on servers provided by a service provider appointed by us. Our service provider is:
IT-BO

The servers automatically collect and store information in server log files, which your browser automatically transmits when you visit the website. The stored information includes:

• Browser type and version
• Operating system used
• Referrer URL
• Host name of the accessing computer
• Date and time of the server request
• IP Address

This data is not merged with other data sources. The collection of this data is based on Art. 6 Para. 1 lit. f GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimisation of its website – server log files must be collected for this purpose.

The location of the website server is in Germany.

As soon as wording contradictions arise, the German version takes precedence.