Privacy Statement

Background to this statement

Your privacy is of crucial importance to Centi.

This Privacy Statement describes how Centi collects, processes and protects your personal data. Centi processes your personal data in compliance with the applicable regulation protecting personal data, and with the utmost respect.

This Privacy Statement also contains information on Centi’s use of cookies and similar technologies.

If you wish to contact Centi about processing of your personal data, our contact information is found at the bottom of this document.

Scope

This Privacy Statement applies when you:

(1) Use Centi’s equity management platform (the “Centi Platform”) with a personal account.

Please note that, if you are using the Centi Platform with a customer account as a representative of one of our customers, Centi will process your personal data on behalf of our customer (the “Centi Customer”) and on the Centi Customer’s instructions. The Centi Customer (e.g., your employer or customer) is therefore the data controller and Centi acts as a data processor. If you are using the Centi Platform with a customer account, please contact the company which has authorized you with the customer account for information about their data processing.

(2) Visit www.gocenti.com and associated pages and sites (the ”Website”)

(3) Applies for a job at Centi

(4) Gets in contact with Centi in your work or assignment with a Centi Customer

(5) Gets in contact with Centi in your work or assignment with a potential Centi Customer

Personal data is information that can identify you as a person, such as an email address, street address or phone number.

This Privacy Statement is published with the aim to make it easy for our users, customers and the public to understand what personal data we collect, store and process, why we do so, how we receive and/or obtain that information, and the rights an individual has with respect to their data in our possession.

This Privacy Statement applies when you:

(1) Use Centi’s equity management platform (the “Centi Platform”) with a personal account.

(2) Visit www.gocenti.com and associated pages and sites (the ”Website”)

(3) Applies for a job at Centi

(4) Gets in contact with Centi in your work or assignment with a Centi Customer

(5) Gets in contact with Centi in your work or assignment with a potential Centi Customer

Personal data is information that can identify you as a person, such as an email address, street address or phone number.

This Privacy Statement applies when you:

(1) Use Centi’s equity management platform (the “Centi Platform”) with a personal account.

(2) Visit www.gocenti.com and associated pages and sites (the ”Website”)

(3) Applies for a job at Centi

(4) Gets in contact with Centi in your work or assignment with a Centi Customer

(5) Gets in contact with Centi in your work or assignment with a potential Centi Customer

Personal data is information that can identify you as a person, such as an email address, street address or phone number.

When you Use the Centi Platform with a Personal Account

The charter below describes how Centi is processing your personal data when you use the Centi Platform with a personal account.

Purpose for the processing

Personal Data

Legal Basis

Retention Period

To set up and administer your account in the Centi Platform and to be able to deliver the Centi Platform to you in accordance with our Terms of Use.

Contact information provided by you or a Centi Customer (name, addresses, email, phone number, social security number).

By agreeing to the Terms of Use in order to use the Centi Platform, you enter into an agreement with us. The processing of this personal data is based on our fulfilment of this agreement.

As long as you are an investor in any company owned by the Customer or any of its parent companies or subsidiaries, and as long as you have a Centi account.

Improve and develop quality, functionality and user experience of the Centi Platform.

Technical identifiers (IP-address, geographic location, Centi unique user id, browser information (type and device).

Our legitimate interest to improve the Centi Platform.

As long as you are an investor in any company owned by the Customer or any of its parent companies or subsidiaries, and as long as you have a Centi account.

Offer support, education and other useful interaction types to Users of the Centi Platform

Contact information provided by you or a Centi Customer (name, addresses, email, phone number, social security number).

Financial information provided by you or a Centi Customer.

Our legitimate interest to communicate and provide support to our users.

As long as you are an investor in any company owned by the Customer or any of its parent companies or subsidiaries, and as long as you have a Centi account.

Being able to operate the Centi Platform, including maintaining, debugging and developing the technical platform.

Technical identifiers (IP-address, geographic location, Centi unique user id, browser information (type and device).

Contact information provided by you or a Centi Customer (name, addresses, email, phone number, social security number).

Financial information provided by you or a Centi Customer.

Our legitimate interest of being able to operate the Centi Platform.

As long as you are an investor in any company owned by the Customer or any of its parent companies or subsidiaries, and as long as you have a Centi account.

Most of the personal data listed above are collected directly from you, i.e. when you register an account in the Centi Platform.

We will also process data about you through cookies. For further information about our use of cookies and how you can change these settings we refer to the about cookies information below.

In addition, Centi Customers may also insert personal data about you on the Centi platform: for instance, if you are a shareholder in company A, company A may include personal information about you (such as your name and address) in their registry of shareholders in the Centi Platform. This holds true even if you have never registered as a user or interacted with Centi in any way. In the situation where personal data about you is registered by a Centi Customer, that Centi Customer is the Data Controller of your personal data. If you have privacy concerns or any questions in this situation, we recommend that you contact that company.

If a Centi Customer is linked to your account in the Centi Platform, personal data connected to your account may also be shared and disclosed to that Centi Customers. For instance, if a Centi Customer lists you as a shareholder, and you register your address and a profile picture in your account, your address and profile picture will be copied to the shareholder register entry in that Centi Company.

Depending on your privacy settings, also other types of personal data may be shared to Centi Customers or to other users. If you wish to configure the privacy settings in your account, please contact us at the contact information stated below.

When you visit our website

The charter below describes how Centi is processing your personal data when you visit our Website. We will also process data about your visit on the Website through Cookies. For further information about our use of Cookies and how you can change these settings we refer to the information about cookies below.

Purpose for the processing

Personal Data

Legal Basis

Retention Period

Improve and develop quality, functionality and user experience of our Website.

Technical identifiers (IP-address, geographic location, Centi unique user id, browser information (type and device).

Our legitimate interest to improve our Website.

5 years.

When you Apply for a job at Centi

The charter below describes how Centi is processing your personal data if you apply for a job at Centi.

Purpose for the processing

Personal Data

Legal Basis

Retention Period

Evaluate potential for becoming a Centi employee

-Name

-Contact details, including email, address and telephone nummer,

-CV and personal letter

Our legitimate interest to find the best candidates to hire.

Until application is closed.

When you Get in contact with Centi in your work or assignment with a Centi Customer

The charter below describes how Centi is processing your personal data if you get in contact with Centi in connection with your work or assignment with any of our Centi Customers.

Purpose for the processing

Personal Data

Legal Basis

Retention Period

Administer and fulfil our customer agreements, as well as handling demands and contact requests from customers.

Contact information provided by you or a Centi Customer (name, addresses, email, phone number, social security number).

Financial information provided by you or a Customer.

Our legitimate Interest to fulfil our customer agreements.

As long as you are an investor in any company owned by the customer or any of its parent companies or subsidiaries.

When you Get in contact with Centi in your work or assignment at a Potential customer

The charter below describes how Centi is processing your personal data if you get in contact with Centi in connection with your work or assignment with any of our Centi Customers.

Purpose for the processing

Personal Data

Legal Basis

Retention Period

To market our business and sell our products and services[S1] [JG2] [S3] [S4].

To market our business and sell our products and services [S1] [JG2] [S3] [S4].

Contact information provided by you or a potential Centi customer (name, addresses, email, phone number).

Our legitimate interest to market and grow our business.

5 years

Data we share

Centi does not share your personal data with any third parties, unless:

a) You consent to a particular sharing of your data with a particular third party.

b) The third party is engaged as a data processor and we have entered into a data processing agreement with that party.

c) Public authorities legally require it. Centi may be demanded to hand over personal information about you to e.g. police or courts, by court order or other legal instruments.

Your rights

You have the right to opt out of any consents to usage of your personal data you have offered, and to demand corrections of personal data about you that Centi controls. In such an event, depending on the nature of your request, some or all of your personal data within Centi will be deleted, altered, blocked or anonymized.

To be more specific,

(a) You have the right to access your personal data and to get it exported. You can request us to inform you about what personal data we have collected about you, and you can request a copy of that personal data.

(b) You have the right to rectify your personal data. You can request us to correct any inaccuracies in your personal data, provided you inform us of the corrections. If you are a Registered User, you can usually correct data yourself by logging onto Centi and accessing your account.

(c) You have the right of erasure. You can request us to delete your personal data on Centi. Depending on the circumstances, you may be entitled to demand the deletion to be carried out before usual data retention periods expire.

(d) You have the right of objection. In some circumstances, you may object to the way we process your personal data.

In some instances, despite your request to the contrary, Centi may be legally allowed to or obliged to keep your personal data unaltered, for instance in order to comply with regulation. In such cases, we will inform you about why we cannot fulfil your request or what partial fulfilment we can offer.

To assert your rights pertaining to personal data about you controlled by Centi, you can contact us using the contact information found below.

To assert your rights pertaining to personal data about you, processed by Centi as a Data Processor on behalf of a Centi Customer (the Data Controller), please make your request with that Centi Customer. For instance, if a company on the Centi Platform lists an incorrect amount of shares held for you as a shareholder in that company's shareholder register on Centi, please contact that company, not Centi, in order to rectify the data.

Security and privacy

In the course of handling your personal data, Centi will store your personal data safely, keep it confidential, and comply with the applicable requirements on the appropriate technical and organisational security measures to ensure an adequate level of protection of your personal data: Centi keeps your data safe on the application level (via authentication and account-level authorizations), on the communication level (by encrypting traffic to and from Centi), and on the data level, by frequently backing up your data. We also have logging and auditing in place for incident analysis and continuous security improvements. In the unlikely event of data loss, Centi is not liable for any claims related to such incidents.

When using subcontractors, Centi will enter Data Processing Agreements with each subcontractor to make sure your personal data is as well-protected as if it were in Centi's hands. Most of the time, your data physically resides in the EU, but in some cases, your personal data may be exported outside the EU, for instance in case of backing up an encrypted database in a US-located data centre. Whenever data is exported outside the EU, Centi makes sure apply appropriate safeguards for the transfer, such as enter into the European Commission’s Standard Contractual Clauses (SCCs) with the data importer. [S1] [S2] You can acquire further information regarding the transfer by contacting us by using the contact details set forth below.

A non-exhaustive list of some of our more central subcontractors is:

Auth0, provider of an authentication service for the users logging on to the Centi platform
AWS, provider of secure cloud storage for files uploaded to the Centi platform

For transparency reasons and to comply with the most common needs of users and companies on Centi, your privacy settings default to a reasonable level of information sharing with other users and companies on Centi. We urge you to regularly ensure that your Centi account privacy settings reflect your wishes. If you wish to configure your privacy settings, please contact us.

Use of cookies and similar technologies

A cookie is a file that is stored on your computer's hard drive, smartphone or any other IT device. It allows for recognition of your computer/IP address and for collection of information about the websites you visit and which features you use.

Centi uses cookies and similar technologies on its Website and the Centi Platform to optimise your visit, when browsing our website, to combat fraud, to generate statistics on the use of our website and for the purposes of marketing, including targeted marketing. By using cookies, Centi registers your activity on the Website to help customise and improve your experience and use of Centi's different features. Centi also uses usage statistics tools such as Google Analytics to collect information on the use of the website, e.g. on how the different functionalities are being used, and how users navigate the site. You can find information of the cookies we use on our Website and in the Centi Plattform in the charter below.

Type of cookie

Cookie name

Purpose

Personal data processed

Duration

Location of processing

Essential [xs]

XSRF-TOKEN

Used for security reasons