Purpose,Scope and Users Star Storage SA, hereinafter referred to as the “Company”, strives to comply with applicable laws and regulations related to Personal Data protection in countries where the Company operates. This Policy sets forth the basic principles by which the Company processes the personal data of consumers, customers, suppliers, business partners, employees and other individuals, and indicates the responsibilities of its business departments and employees while processing personal data. This Policy applies to the Company and its directly or indirectly controlled wholly-owned subsidiaries conducting business within the European Economic Area (EEA) or processing the personal data of data subjects within EEA. The users of this document are all employees, permanent or temporary, and all contractors working on behalf of The Company. Definitions The following definitions of terms used in this document are drawn from Article 4 of the European Union’s General Data Protection Regulation: Personal Data: Any information relating to an identified or identifiable natural person (“Data Subject”) who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Sensitive Personal Data: Personal data which are, by their nature, particularly sensitive in relation to fundamental rights and freedoms merit specific protection as the context of their processing could create significant risks to the fundamental rights and freedoms. Those personal data include personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Data Controller: The natural or legal person, public authority, agency or any other body, which alone or jointly with others, determines the purposes and means of the processing of personal data. Data Processor: A natural or legal person, public authority, agency or any other body which processes personal data on behalf of a Data Controller. Processing: An operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of the data. Anonymization: Irreversibly de-identifying personal data such that the person cannot be identified by using reasonable time, cost, and technology either by the controller or by any other person to identify that individual. The personal data processing principles do not apply to anonymized data as it is no longer personal data. Pseudonymization: The processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person. Pseudonymization reduces, but does not completely eliminate, the ability to link personal data to a data subject. Because pseudonymized data is still personal data, the processing of pseudonymized data should comply with the Personal Data Processing principles. Cross-border processing of personal data: Processing of personal data which takes place in the context of the activities of establishments in more than one Member State of a controller or processor in the European Union where the controller or processor is established in more than one Member State; or processing of personal data which takes place in the context of the activities of a single establishment of a controller or processor in the Union but which substantially affects or is likely to substantially affect data subjects in more than one Member State; Supervisory Authority: An independent public authority which is established by a Member State pursuant to Article 51 of the EU GDPR; Lead supervisory authority: The supervisory authority with the primary responsibility for dealing with a cross-border data processing activity, for example when a data subject makes a complaint about the processing of his or her personal data; it is responsible, among others, for receiving the data breach notifications, to be notified on risky processing activity and will have full authority as regards to its duties to ensure compliance with the provisions of the EU GDPR; Each “local supervisory authority” will still maintain in its own territory, and will monitor any local data processing that affects data subjects or that is carried out by an EU or non-EU controller or processor when their processing targets data subjects residing on its territory. Their tasks and powers includes conducting investigations and applying administrative measures and fines, promoting public awareness of the risks, rules, security, and rights in relation to the processing of personal data, as well as obtaining access to any premises of the controller and the processor, including any data processing equipment and means. “Main establishment as regards a controller” with establishments in more than one Member State, the place of its central administration in the Union, unless the decisions on the purposes and means of the processing of personal data are taken in another establishment of the controller in the Union and the latter establishment has the power to have such decisions implemented, in which case the establishment having taken such decisions is to be considered to be the main establishment; “Main establishment as regards a processor” with establishments in more than one Member State, the place of its central administration in the Union, or, if the processor has no central administration in the Union, the establishment of the processor in the Union where the main processing activities in the context of the activities of an establishment of the processor take place to the extent that the processor is subject to specific obligations under this Regulation; Group Undertaking: Any holding company together with its subsidiary. Principles Regarding Personal Data Processing The data protection principles outline the basic responsibilities for organisations handling personal data. Article 5(2) of the GDPR stipulates that “the controller shall be responsible for, and be able to demonstrate, compliance with the principles.” Lawfulness, Fairness and Transparency Personal data must be processed lawfully, fairly and in a transparent manner in relation to the data subject. Purpose Limitation Personal data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Data Minimization Personal data must be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed. The Company must apply anonymization or pseudonymization to personal data if possible to reduce the risks to the data subjects concerned. Accuracy Personal data must be accurate and, where necessary, kept up to date; reasonable steps must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified in a timely manner. Storage Period Limitation Personal data must be kept for no longer than is necessary for the purposes for which the personal data are processed. Integrity and confidentiality Taking into account the state of technology and other available security measures, the implementation cost, and likelihood and severity of personal data risks, the Company must use appropriate technical or organizational measures to process Personal Data in a manner that ensures appropriate security of personal data, including protection against accidental or unlawful destruction, loss, alternation, unauthorized access to, or disclosure. Accountability Data controllers must be responsible for and be able to demonstrate compliance with the principles outlined above. Data Protection in Activities Collection The Company must strive to collect the least amount of personal data possible. If personal data is collected from a third party, DPO must ensure that the personal data is collected lawfully. Use, Retention, and Disposal The purposes, methods, storage limitation and retention period of personal data must be consistent with the information contained in the Privacy Notice. The Company must maintain the accuracy, integrity, confidentiality and relevance of personal data based on the processing purpose. Adequate security mechanisms designed to protect personal data must be used to prevent personal data from being stolen, misused, or abused, and prevent personal data breaches. DPO is responsible for compliance with the requirements listed in this section. Disclosure to Third Parties Whenever the Company uses a third-party supplier or business partner to process personal data on its behalf, DPO must ensure that this processor will provide security measures to safeguard personal data that are appropriate to the associated risks. When the Company processes personal data jointly with an independent third party, the Company must explicitly specify its respective responsibilities of and the third party in the relevant contract or any other legal binding document, such as the Supplier Data Processing Agreement. Cross-border Transfer of Personal Data Before transferring personal data out of the European Economic Area (EEA) adequate safeguards must be used including the signing of a Data Transfer Agreement, as required by the European Union and, if required, authorization from the relevant Data Protection Authority must be obtained. The entity receiving the personal data must comply with the principles of personal data processing set forth in Cross Border Data Transfer Procedure. Rights of Access by Data Subjects When acting as a data controller, DPO is responsible to provide data subjects with a reasonable access mechanism to enable them to access their personal data, and must allow them to update, rectify, erase, or transmit their Personal Data, if appropriate or required by law. Data Portability Data Subjects have the right to receive, upon request, a copy of the data they provided to us in a structured format and to transmit those data to another controller, for free. DPO is responsible to ensure that such requests are processed within one month, are not excessive and do not affect the rights to personal data of other individuals. Right to be Forgotten Upon request, Data Subjects have the right to obtain from the Company the erasure of its personal data. When the Company is acting as a Controller, DPO must take necessary actions (including technical measures) to inform the third-parties who use or process that data to comply with the request. Fair Processing Guidelines Personal data must only be processed when explicitly authorised by DPO. Notices to Data Subjects At the time of collection or before collecting personal data for any kind of processing activities including but not limited to selling products, services, or marketing activities, DPO is responsible to properly inform data subjects of the following: the types of personal data collected, the purposes of the processing, processing methods, the data subjects’ rights with respect to their personal data, the retention period, potential international data transfers, if data will be shared with third parties and the Company’s security measures to protect personal data. This information is provided through Privacy Notice. Where personal data is being shared with a third party, DPO must ensure that data subjects have been notified of this through a Privacy Notice. Where personal data is being transferred to a third country according to Cross Border Data Transfer Policy, the Privacy Notice should reflect this and clearly state to where, and to which entity personal data is being transferred. Where sensitive personal data is being collected, the Data Protection Officer must make sure that the Privacy Notice explicitly states the purpose for which this sensitive personal data is being collected. Consent Whenever personal data processing is based on the data subject’s consent, or other lawful grounds, DPO is responsible for retaining a record of such consent. DPO is responsible for providing data subjects with options to provide the consent and must inform and ensure that their consent (whenever consent is used as the lawful ground for processing) can be withdrawn at any time. Where collection of personal data relates to a child under the age of 16, DPO must ensure that parental consent is given prior to the collection. When requests to correct, amend or destroy personal data records, DPO must ensure that these requests are handled within a reasonable time frame. DPO must also record the requests and keep a log of these. Response to Personal Data Breach Incidents When the Company learns of a suspected or actual personal data breach, DPO must perform an internal investigation and take appropriate remedial measures in a timely manner, according to the Data Breach Policy. Where there is any risk to the rights and freedoms of data subjects, the Company must notify the relevant data protection authorities without undue delay and, when possible, within 72 hours. Conflicts of Law This Policy is intended to comply with the laws and regulations in the place of establishment and of the countries in which SC Star Storage SA operates. In the event of any conflict between this Policy and applicable laws and regulations, the latter shall prevail.