Privacy Statement

Colbright, located in the Netherlands and registered with the Chamber of Commerce under number 17171530, is committed to respecting your privacy, and recognize the need for appropriate protection and management of any Personal Data that you may provide us.

This Privacy Statement explains our practices with respect to Personal Data we collect and process in connection with your relationship with us and applies to all Websites and Services owned and operated by Colbright.

This includes Personal Data we collect:

• through our website;
• when you interact with us through social media;
• through business relationships that you or your organization maintains with us;
• when you request marketing or promotional material from us.

We encourage you to review this Privacy Statement to understand how we collect, process, use, share, and safeguard your Personal Data. If you have any questions, comments, or complaints about our practices, please contact us as described at the end of this Privacy Statement.

Data Protection Officer

Due to the nature of Colbright’s core business, it is not legally required to install a Data Protection Officer and Colbright has therefor chosen not to appoint one.

Personal Data We Collect

We may collect Personal Data from you and about you from a variety of sources. We strive to only collect Personal Data that is adequate, relevant, and limited to achieve the purpose(s) for which it was collected. In addition, we strive to keep all Personal Data accurate, complete, and reliable for its intended need, and we only retain your Personal Data for as long as necessary to achieve the purpose(s) for which it was collected.

Examples of the ways in which we collect your Personal Data include:

When expressing an interest in obtaining additional information about Colbright’s products and services (for example through the request form on our website), we require you to provide the following personal information, such as: Name, company name, job title, email address, mailing address, phone number.

When you purchase Colbright’s solutions or services, we will also require you to provide billing information, additional contact information for support purposes.

As you navigate the Company’s Web site, Colbright may also collect information through the use of commonly used information gathering tools such as google analytics, web beacons and cookies. Information collected includes standard information from your web browser such as your Internet Protocol (IP) address, browser type, operating system, referring/exit pages, links clicked, and actions taken while browsing.

How We Use Your Personal Data

We may use your Personal Data for one or more of the following business purposes:

• to provide you or the business with which you are associated with requested product or service information;
• to provide you or the business with which you are associated with certain personalized services, including negotiation, execution, and management of (customer) contracts;
• to support our internal activities, such as marketing, product and service development, dissemination of investor information, and recruiting;
• to support our relationship with you and the business with which you are associated, including customer or technical support services, and accounting and billing services;
• to support certain internal processes to ensure protection of property and interests for both Colbright and its customers, including fraud detection, internal auditing, supporting internal and external investigations, and conducting security assessments;
• to inform you or the business with which you are associated of our products and services, and provide you with our latest information and news about us;
• to respond to inquiries regarding career opportunities;
• to enable you to contact us, and for us to respond to you; and
• to analyze the use of our website in order to develop and enhance the services we may provide to you and the business with which you are associated.

Disclosure of Your Personal Data to Third Parties

We will not disclose your Personal Data to any third party except as follows:

• We may share your Personal Data with our affiliated companies;
• We may share your Personal Data with third parties when you ask us to do so (such as when you make a request for data portability);
• We may share your Personal Data with our contracted service providers, suppliers, and third-party processors, such as third-party marketing service providers acting on our behalf and under our instructions. These providers are authorized to use your Personal Data only as necessary to provide us their services.

We do not sell your Personal Data to any third parties, whether for monetary or other valuable consideration, and have not done so in the prior 12 months. If we disclose your Personal Data as outlined above, we do so to facilitate the relevant services or our relationship with you and not for direct renumeration. Where we engage any service provider that will require access to and use of Personal Data to provide certain services for and under the instructions of Colbright, we take reasonable steps to ensure such service provider complies with applicable data protection and privacy laws.

Finally, we reserve the right to disclose your Personal Data if required to do so by law, in the good faith belief that such action is reasonably necessary to comply with applicable law, or to protect the rights, property, or safety of Colbright, its employees, customers, or the public.

Security

The security of your personal information and our Customers’ information is important to us. When you enter sensitive information (such as login credentials) on our platforms login, we encrypt the transmission of that information using secure socket layer technology (SSL). We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

If you have any questions about security on our Web site or with our products, you can contact us at: info@colbright.com

Data Retention

Colbright will retain your information for as long as your account is active or as needed to provide you services, and as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, or as otherwise reasonably necessary for our business purposes.

Correcting and Updating Your Information

Upon request Colbright will provide you with information about whether we hold any of your personal information. To review and update your personal information to ensure it is accurate, contact us at info@colbright.com. We will respond to all requests for access, to correct inaccurate data, update information, or delete information within 30 business days.

Collection of Personal Data Information from Minors

We do not knowingly collect Personal Data from children under the age of 16. By using our services, you represent that you are 18 years of age or older.

Business Transfers

We may, in the future, sell or otherwise transfer some or all of our business, operations, or assets to a third party, whether by merger, acquisition or otherwise. We may disclose Personal Data we obtain from or about you to any potential or actual third-party acquirers, and it may be among the assets transferred.

Your Rights

Depending on applicable data protection and privacy laws, you may be entitled to a variety of legal rights regarding the collection and processing of your Personal Data. You may exercise these rights, to the extent they apply to you, by contacting us at info@colbright.com

Note, however, that we may request certain reasonable additional information (that may include Personal Data) to help us authenticate your identity, your request, and/or to clarify or understand the scope of such requests.

These rights vary depending on the particular laws of the jurisdiction applicable to you, but may include:

• the right to know whether, and for what purposes, we process Personal Data;
• the right to access, modify, or correct Personal Data about you;
• the right to delete Personal Data about you;
• the right to limit the processing of your personal data;
• the right to know with whom we have shared your Personal Data, for what purpose, and what Personal Data has been shared;
• the right to withdraw your consent (when processing of Personal Data is based on consent);
• the right to lodge a complaint with a regulator, including relevant supervisory authorities, located in the jurisdiction of your residence, place of work, or where an alleged violation of law occurred.

Where required by applicable law, we will respond to a valid request relating to your rights within 30 business days of receipt, or within 60 business days where a request is complex or challenging.

Depending on the type of personal data in question and the grounds on which we are processing it, should you decline to provide us with such data or ask us to stop processing it, we may not be able to fulfil our contractual requirements or, in extreme cases, may not be able to continue with our relationship or may have to bring that relationship to a close (i.e. because we cannot continue it without personal data about you).

Contact

In case of any questions please get in contact via info@colbright.com