This Privacy Notice explains how Linical Europe Holding GmbH, and its affiliates, subsidiaries and branch offices established in the European Union (each as a “Linical Europe Holding EU entity” or together “we” or “us”), collect, use and disclose personal data online and offline in connection with the services we provide to our clients (“Services”). We refer to the individuals whose Personal Data (as described below) we process, i.e. a natural person who works for or is otherwise engaged by, or interact with us (including Linical employees and officers, freelancers, employees of our vendors, service providers and agents), our clients (including clients employees, officers and agents), their affiliates or other third parties in connection with the Services, as “you” in this Notice.

1. WHAT WE NEED
   Linical Europe Holding is a Controller of the personal data you (data subject) provide us. We collect the following types of personal data from you:
   • Name
   • Account details and contact information
   • Postal Address
   • Telephone Number or fax number
   • Email address and other identifying addresses for electronic communications
   • Date of birth
   In the course of providing certain Services, we may also receive from you, or third parties, information including:
   • Employment related information (salary information, stock options, shareholdings, pension, and CVs);
   • Family information
2. WHY WE NEED IT
   We need to collect and process Personal Data in order to provide the requested Services, or because we are legally required to do. If we do not receive the information that we request, we may not be able to provide the requested Services. We may use Personal Data for our legitimate business interests, including the following:
   • To validate authorized signatories when concluding agreements and transactions;
   • To contact nominated individuals in connection with the existing transactions and contractual agreements;
   • To respond to enquiries and fulfil requests from our clients and/or relevant third parties who require information as a necessary part of the provision of the Services, and to administer account(s) and manage our relationships;
   • To inform our clients about products or services which we believe may be of interest, including tailored ads, marketing proposals or offers;
   • To verify an individual’s identity and/or location (or the identity or location of our client’s representative or agent ) ;
   • To protect the security of accounts and Personal Data
   • For information and relationship management purposes, and business purposes, including data analysis, audits, developing and improving products and services, identifying usage trends and determining the effectiveness of promotional campaigns, and enhancing, improving or modifying our Services;
   • For risk management, compliance with our legal and regulatory obligations and for fraud detection, prevention and investigation, due diligence and verification requirements and tax reporting;
   • To comply with laws and regulations (including any legal or regulatory guidance, codes or opinions), and to comply with other legal process and law enforcement requirements (including any internal policy based on or reflecting legal or regulatory guidance, codes or opinions);
   • To provide, and perform our obligations with respect to, the Services or otherwise in connection with fulfilling instructions; and
   • To send administrative information to clients, such as changes to our terms, conditions and policies.
3. WHAT WE DO WITH IT
   Your personal data is processed in Linical Europe Holding and its affiliates located in in each corresponding location. See Appendix 1 of the Privacy Notice for further details.
   Personal Data may be disclosed to third parties in connection with the Services we are providing. The recipients of any such information will depend on the Services that are being provided. Subject to any restrictions around confidentiality we have expressly agreed with our client or other transaction parties, such disclosures may include disclosures:
   • To affiliates and subsidiaries of Linical Europe Holding GmbH for the purposes described in the Privacy Notice (“affiliates”);
   • To our third party service providers who provide services such as website hosting, data analysis, payment processing, order fulfilment, information technology and related infrastructure provision, customer service, email delivery, auditing and other services;
   • To third party experts and advisers (including external legal counsel, notaries, auditors and tax advisers);
   • To payment, banking and communication infrastructure providers, financial institutions or intermediaries;
   • To third party distribution platforms and to operators of private and common carrier communication or transmission facilities, mail or courier services;
   • To other deal/transaction participants including issuers, borrowers, potential investors and prospectuses and marketing materials and translation service providers
   • Other persons as agreed with our client or as required or expressly permitted by applicable law.
   In additions, we may use, disclose or transfer Personal Data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business to third parties as requested by clients or their representatives.
4. HOW LONG WE KEEP IT
   Under Linical Europe Holding GmbH and its affiliates, we will retain Personal Data for as long as needed or permitted in light of the purposes for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with our client and provide services; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory requirements).
5. SECURITY
   We seek to use reasonable organizational, technical and administrative measures to protect Personal Data within our organization. Unfortunately, no data transmission or storage system can be 100% secure. If you have reason to believe that your Personal Data is no longer secure, please immediately notify us in accordance with the “What are your rights?” section below.
6. WHAT ARE YOUR RIGHTS?
   You have the right to request details about the information we collect about you. If you would like to request to review, correct, update, suppress, restrict or delete Personal Data that you have previously provided to us, or if you would like to request to receive an electronic copy of your Personal Data (to the extent this right to data portability is provided to you by applicable law), you may contact us. In the event that you wish to exercise your rights about how we have handled your personal data, please contact Data Protection Officer (Ana Balmes) at dataprotection@linical.com or in writing at:

   Data Protection Officer Calle Las Norias 92, 2ª planta. Puerta B. Edificio Nuestra Señora del Pilar 28221 Majadahonda, Madrid, Spain

   To help us to manage your query, please include your full name and the location of the Linical Europe Holding affiliate that processed your personal data.

7. JURISDICTION AND CROSS BORDER TRANSFER
   Personal Data may be stored and processed in any country where we have facilities or engage service providers to include the United States and Japan. If you are located in the European Area (EEA): Some none-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries are available here http://ec.europa.eujustice/dataprotection/international-transfers/adequacy/index_en.html . For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect Personal Data. You may obtain a copy of these measures by following this link: http://ec.europa.eu/justice/dataprotection/international-transfers/transfer/index_en.html .
8. USE OF SERVICES BY MINORS
   Our services are not directed to individuals under the age of eighteen (18), we do not knowingly collect Personal Data from individuals under 18.
9. SENSITIVE PERSONAL DATA
   We do not typically collect sensitive Personal Data. Please do not send any Personal Data which would be categorized as special data under GDPR (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership).
10. UPDATES TO THIS PRIVACY NOTICE
    We may change this Privacy Notice, including the list of affiliates where required. Any changes will become effective when we post the revised Privacy Notice.