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Privacy policy of Levenue

Version: August, 2021
The Levenue Platform is operated and managed by LevenueB.V., a private company with limited liability incorporated under the Dutch law, having its seat in Breda, The Netherlands, and its registered office at Markendaalseweg 44, 4811KC Breda, The Netherlands and registered with the Dutch Commercial Register under number 862436400. Levenue B.V. controls the collection and processing of any personal data that you provide to us in relation to the Levenue Platform. Where services are provided to you by any affiliate of LevenueB.V., the entity providing the service will be responsible for the processing of your personal data. This privacy policy applies to all such entities. Levenue B.V. and any such entities are jointly referred to in this privacy policy as "Levenue", "we" or "us".
Levenue collects personal data when you use the Platform, register as a user and contact us. "Personal data" is any information that relates to you or any identified or identifiable individual and that identifies you or that individual either directly from that information or indirectly, by reference to other information that we have access to.
Levenue is committed to respecting and protecting the privacy of the individuals on whom it holds information. All your personal data will be processed in accordance with applicable data protection laws, including the European Regulation 2016/679 on the protection of natural persons with regard to the processing of personal date and on the free movement of such data (the "General Data protection Regulation" or "GDPR"), as amended from time to time.
This privacy policy describes the personal data that we collect from you, the purposes of our processing of your personal data, the legal basis for our processing of your personal data, whether any third parties may access your personal data, the retention period applicable in respect of your personal data, and your rights regarding your personal data. This privacy policy applies to the relationship between you and Levenue, together with the relevant provisions of the Terms of Use of the Platform https://www.levenue.com/terms and the Cookies Policy https://www.levenue.com/cookies.
1. Contact details
If you have any question regarding this privacy policy or our processing of your personal data or if you want to exercise your rights with regards to your personal data, you may contact us at:

Levenue B.V. Markendaalseweg 44,
4811KC Breda, The Netherlands,

legal@levenue.com
2. Personal data we collect
2.1
When you use the Platform, we collect the following categories of personal data:
2.1.1
identification data suchas user account information (if any), name, email address;
2.1.2
technical data such as your IP address, your operating system, your browser type;
2.1.3
behavioural data such as the manner in which you use the Platform and how you interact with the Platform.
2.2
When you register for a user account, we collect the following categories of personal data:
2.2.1
contact information such as email address, name and surname, telephone number and address;
2.2.2
biographical information such as employer and job title;
2.2.3
communication preferences such as preferred language;
2.2.4
technical data such as your IP address, your operating system.
2.3
If you contact us to inform us of any queries you may have, we will collect the following categories of personal data:
2.3.1
identification data and contact information such as you user account (if any), email address or phone number;
2.3.2
the content of your correspondence with us.
2.4
When you register for our newsletter, we collect the following categories of personal data:
2.4.1
identification data and contact information such as you user account (if any), email address or phone number;
2.4.2
technical data such as information on your device and your IP address;
2.4.3
behavioural data such as links opened, click throughs;
2.4.4
communication preferences.
3. The purposes of our processing of your personal data
We collect your personal data for the following purposes:
a)
to allow you to access and use the Platform;
b)
to set up and maintain your user account and your access to youraccount;
c)
to communicate with you and provide you with appropriate support;
d)
to improve, effectively present and personalise our services by using the analytical services of third parties to evaluate your use of the website, create reports on the activity, collect demographic data, analyse performance data, and collect other data on our website and Internet usage. These third parties use cookies and other technology to help analyse the data and to provide the data to us. Please see our Cookie Policy https://www.levenue.com/cookies for more info;
e)
for fraud and money laundering prevention and detection and to comply with applicable laws and regulations;
f)
to match users trading on the Platform to the organisations on behalf of such trading is effectuated, in order to ensure that such user is entitled to effectuate that trade.
We are committed to safeguarding and protecting your personal data and using it lawfully, fairly and in a transparent way, in compliance with the GDPR, and we will only collect and process your personal data for the specified and explicit purposes listed above.
4. Legal basis for the processing of your personal data
We are allowed to process your personal data if a legally permitted reason applies. These include the following:
a)
Performance of the agreement: we are allowed to process your personal data to communicate with you before entering into our business relationship, to deliver our services and to fulfil a contract with you. For example, we need your contact details to be able to create a user account.
b)
Legitimate interest: we may process your personal data when it is in our legitimate interest to do so. For instance, we collect your behaviour data to improve our services and the Platform.
c)
Consent: we may also process your personal data if we have your express consent, e.g. when you register for a newsletter or when you agree to the use of specific cookies.
d)
Legal obligation: we may process your personal data to comply with our legal and regulatory obligations, such as anti-money laundering and fraud and crime prevention.
5. Retention and deletion
Levenue may retain your personal data as necessary for internal analytical purposes, or to provide you with services that you have requested, comply with its legal obligations, resolve disputes and enforce agreements (e.g. settlement). The criteria used to determine the retention periods include:
a)
how long the personal data is needed to provide the services and operate the business;
b)
the type of personal data collected; and
c)
whether Levenue is subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).
If you would like more information about applicable data retention policies, please contact our privacy team via the contact details provided in Section 1. of this privacy policy.
6. Your rights as data subject
Under the GDPR, you are entitled to exercise certain rights regarding how we use and keep your personal data. You can exercise your rights by contacting our privacy team via the contact details provided in Section 1. of this privacy policy. They are the following:
6.1.1
Right for information and access
You are always entitled to know what personal data we hold about you and how, where and for how long such personal data are processed. You therefore have the right to request information regarding the personal data that we hold and process concerning you and to access such personal data. Upon your request, we will provide you with information and/or access to the personal data that is being processed and the source of such personal data. Please note that we may request you to provide us with satisfactory proof of your identity before complying with your request for information or access.
6.1.2
Right of rectification and right of erasure
You have the right to request us, free of charge, to rectify any inaccurate personal data, or to complete any incomplete personal data, concerning you. You may also have the right, in certain circumstances, to require us, free of charge, to erase all your personal data, without undue delay.
6.1.3
Right to object to data processing
You have the right at any time to object to the processing of your data on grounds relating to your particular situation. If you object, we will no longer process your personal data unless we can prove compelling legitimate reasons for the processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.In case we process your personal data for direct marketing purposes (such as our newsletter), and you do not wish to receive advertising, you have the right to object to this at any time. If we receive such objection from you, we will stop processing your data for direct marketing purposes.
6.1.4
Right to withdraw your consent
You may, at any time, withdraw the consent that you have given to Levenue to the processing of your personal data. Please note that if you withdraw your consent, that does not make the data processing carried out by us prior to receiving your request unlawful.
6.1.5
Right to restriction
You have the right to "restrict" our use of your personal data where: (i) you contest the accuracy of the personal data, (ii) the processing is unlawful and you request us to "restrict" our use of your personal data rather than to erase it;(iii) we no longer need the personal data for the original purpose of the processing but they are required by you for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing and there is a verification of whether our legitimate grounds can override yours.
6.1.6
Right to data portability
Within the limits set forth in the GDPR, you may request the portability of your personal data, i.e. obtain that the personal data you have provided to Levenue be returned to you or transferred to someone else of your choice, in a structured, commonly used and machine-readable format.
6.1.7
Right to lodge a complaint with the competent authority
If you are not satisfied with the way we process your personal data, please contact our privacy team via the contact details provided in Section 1. of this privacy policy and we will investigate your concern. You also have the right to lodge a complaint with a supervisory authority. In the Netherlands, thesupervisory authority is the Autoriteit Persoonsgegevens (address:Bezuidenhoutseweg 30, 2594 AV The Hague, The Netherlands, website: https://autoriteitpersoonsgegevens.nl).
7. Disclosures to third parties and transfers to third parties
2.1
Disclosures and/or to third parties
Other than as set out in this privacy policy, Levenue will not sell or otherwise disclose your personal data to third parties without obtaining your prior explicit consent, unless this is necessary for the relevant purpose set out in this privacy policy or we are required to do so by law.

We may share personal data with third party cloud providers and service providers who help us to provide, understand, commercialise and improve the Platform and our services. We do not authorise these third-party service providers to use or disclose your personal data except as strictly necessary to perform any services under our supervision or to comply with applicable laws. We seek to provide any such third-party service provider with only the personal data they need to perform their specific function.

Levenue puts in place contractual (including data protection, confidentiality and security provisions) and other organisational safeguards with third-party service provides who have access to your personal data to ensure an adequate level of protection of your personal data.

At the date of this privacy policy, Levenue uses the following third-party providers:
a) Salt Edge;
b) Vercel;
c) SendGrid;
d) MessageBird;
e) Google – G Suite;
f) AWS;
g) DocuSign;
h) Stripe;
i) Chargebee;
j) Recurly.
2.1
Transfers to third countries
If recipient of your personal data is located in a non-EEA country and this country is not recognised by the European Commission as offering an adequate level of data protection, we will put in place appropriate safeguards to protect your personal data in accordance with the GDPR, such as the Standard Contractual Clauses adopted by the European Commission, if necessary with additional measures.
8. Changes to this Privacy Policy
Levenue reserves the right to change this privacy policy at any time and from time to time in order to reflect changes in the services provided on the Platform or the applicable laws. If Levenue decides to change this privacy policy in the future, Levenue will post an appropriate notice at the top of this privacy policy page and/or give you reasonable advance notice through the Platform. Any non-material change(such as clarifications) to this privacy policy will become effective on the date the change is posted and any material changes will become effective thirty (30) days from their posting on the Platform. The date this privacy policy was last revised appears at the top of this document. Your continued use of the Platform after the changes to this privacy policy become effective signifies that you accept of any such changes.