Privacy Statement 202

Privacy statement regarding the Recharge360 app and web portal

1. INTRODUCTION

When using the Recharge360 app (hereinafter: the "App"), the Recharge360 web portal (hereinafter: the “Portal”), and/or visiting our website at www.recharge360.com (hereinafter: the "Website"), personal data is collected by Recharge360 B.V. (hereinafter: "Recharge360"). In this privacy statement (the "Privacy Statement") we inform you, among other things, about the types of personal data Recharge360 collects and uses, the purpose, for how long and how that personal data is protected. We also inform you of your rights with respect to the processing of your personal data, whether you are a registered user or simply a Website visitor. Recharge360 attaches great importance to careful handling and protection of personal data. The processing of personal data by Recharge360 is fully in line with the General Data Protection Regulation (hereinafter: "GDPR") and other applicable laws and regulations.

2. WHAT IS THE ROLE OF Recharge360?

Recharge360 is seen as the controller in the sense of the GDPR. The controller has certain statutory duties and responsibilities with respect to its processing activities. The controller is also the entity to whom you can turn for questions about the processing of your personal data and to whom you can exercise your rights. More information on this can be found in Articles 8 and 9 of this Privacy Statement.

3. HOW DOES Recharge360 COLLECT OR RECEIVE YOUR PERSONAL DATA?

Recharge360 collects or receives your personal data because it is shared by you with Recharge360 via the App, Portal, Website (e.g., through contact forms), chat, email, or phone. We also collect certain data automatically when you browse our Website using cookies and similar technologies. For registered users, your employer may also share certain of your personal data with Recharge360 in order to sign you up as a user of the App / Portal.

4. WHICH PERSONAL DATA DOES Recharge360 PROCESS, FOR WHAT PURPOSES AND ON WHAT LEGAL GROUNDS?

Depending on whether you use the App, Portal, or simply visit the Website, the following personal data may be processed by Recharge360:

• Contact information: name, phone number, home address, and email address;
• Communication: information shared and documented with/by a coach via email, chat messages, and/or over the phone;
• User data (App/Portal only): information about you as a user such as your place of residence, fitness, sleep quality, experience of your workload, mental and physical condition and weight, as well as whether you have performed any of the activities recommended in the App / Portal. It is up to you to decide whether or not you want to share/enter this information in the App / Portal;
• Registration details: username and password;
• Website visitor data: IP address, browser type, device information, pages visited, and interaction data on our Website.

If the information you share concerns special personal data, such as information about your mental or physical health, we will first ask your explicit permission to process this data. All data is also anonymized.

Recharge360 processes the above personal data for the following purposes:

1. To be able to communicate with you;
2. to be able to deliver the service (the App / Portal) to you;
3. to coach you;
4. for optimization of the App, Portal, and Website, and for example to be able to connect the App / Portal to a specific group as much as possible;
5. to enhance the experience of the App / Portal;
6. For relationship management and any marketing activities; and
7. for you as a user to keep track of your development within the App / Portal.

The legal ground for the processing of these personal data is: the necessity for execution of our agreement namely the delivery of the App / Portal and associated services (purposes 1 and 2); the necessity to pursue the legitimate interests of Recharge360 (such as basic website security and analytics), whereby these interests override the interests or the fundamental rights of the person whose personal data we process (purposes 4, 5, and 6); or consent of the person involved (purposes 3, 7, and the use of non-functional cookies).

5. WITH WHOM WILL YOUR PERSONAL DATA BE SHARED?

It may happen that Recharge360 shares your personal data with a third party because: Recharge360 has engaged a third party to provide, for example, the hosting and technical support of the App, Portal, and Website. Where necessary, Recharge360 has concluded a data processing agreement with such third parties; it is necessary to execute the agreement (think for example of an external coach); you have given permission for this, which permission you can withdraw at any time; or Recharge360 is legally obliged to do so. Your personal data will not be shared.

6. HOW DO WE SECURE YOUR PERSONAL DATA?

Recharge360 has taken appropriate technical and organizational measures to protect your personal data in accordance with the GDPR requirements against accidental destruction, loss or damage, and any form of unauthorized and unlawful processing. For example, your personal data is only accessible to employees of Recharge360 for whom it is necessary to access your personal data, authentication is used, all our systems are secured, and we only work with suppliers who guarantee a high level of security.

7. HOW LONG WILL YOUR PERSONAL DATA BE STORED?

The personal data collected by Recharge360 will not be kept for a longer period than necessary for the purpose of processing. In any case, your App/Portal personal data will not be kept longer than 12 months after termination of the agreement (termination of the use of the App / Portal) or the last log-in to the App / Portal. Website visitor data collected via cookies is stored in accordance with the specific lifespans of those cookies, which are detailed in our Cookie Statement. The retention period mentioned above does not apply if there is a legal obligation for Recharge360 to retain the data for a longer period of time.

8. WHAT ARE YOUR RIGHTS?

What are your rights with regard to the personal data that Recharge360 processes? You have the right:

• of access to the personal data that Recharge360 processes about you;
• to rectify incorrect or incomplete personal data;
• to, under certain circumstances, have your personal data erased;
• to, in certain cases, temporary suspension of the processing of your personal data;
• to revoke your consent to processing of your personal data, which right may be exercised at any time;
• To data portability;
• to object to the processing of your personal data because of a reason related to your specific situation;
• to object to direct marketing or tracking cookies. If you object, we will immediately cease processing your personal data for this purpose; and
• to file a complaint with the Personal Data Authority (https://www.autoriteitpersoonsgegevens.nl/) about the processing of your personal data.

9. CONTACT

If you have given permission for the use of your personal data and you want to withdraw this permission, you want to exercise a right as mentioned in Article 8, you have a question about this Privacy Statement, or you wish to object to our use of cookies, you can easily contact Recharge360:

• by sending a letter to Recharge360 attn. Hidde de Vries, Zuid Hollandlaan 7, 2596 AL The Hague;
• by sending an email to info@recharge360.com.

10. COOKIES

Recharge360 uses cookies and similar technologies on the Website, App, and Portal. A cookie is a small text file stored on your device. To ensure you receive consistent and clear information regarding our cookie usage, we align this Privacy Statement with our actual practices. We use the following types of cookies:

• Functional cookies: These are strictly necessary for the Website, App, and Portal to function properly and securely.
• Analytical cookies: We use these to analyze website traffic and improve the user experience.
• Marketing and Tracking cookies: We use these to show relevant advertisements and measure the effectiveness of our campaigns. While the privacy impact of these cookies is generally low as they do not store highly confidential data, they are only placed on your device if you give us your explicit consent.

Managing your preferences:

For detailed information on the specific tracking and analytical cookies we store during your visit, please refer to our separate Cookie Statement / Cookie Banner on the Website. Website visitors can manage their cookie preferences or withdraw their consent at any time via this Cookie Statement. Alternatively, if you wish to object to the use of cookies or have any questions about them, you can always reach out to us directly using the contact details provided in Article 9 of this Privacy Statement.

11. AMENDMENTS TO THIS PRIVACY STATEMENT

Recharge360 reserves the right to make changes to this Privacy Statement. Changes will be published on our website. We advise you to consult this Privacy Statement regularly so that you are aware of these changes.