1. General information PRIVACY STATEMENT This global privacy statement explains how SetPlans LLC LLC protect the personal data SetPlans LLC processes and controls relating to you (“your personal data”), why SetPlans LLC processes your personal data, who has access to your personal data and how you can exercise your rights in relation to the processing of your personal data. Any SetPlans LLC entity located outside the European Union will for the purposes of compliance with data privacy laws be represented by SetPlans LLC LLC. This global privacy statement provides an overview of SetPlans LLC’s most common processing activities of your personal data. Please note that certain specific processing activities may be subject to a separate and tailored privacy statement. In the event any translation of this global privacy statement is prepared, the English version of this global privacy statement shall prevail in case of conflicts between the different language versions. Which categories of personal data does SetPlans LLC process? SetPlans LLC will collect personal data about you to achieve the purposes set out in this global privacy statement. If you provide SetPlans LLC with any personal data of another person (for instance, a potential employee/referral), you are responsible for ensuring that such person is made aware of the information contained in this global privacy statement and that the person has given you his/her consent for sharing the information with SetPlans LLC. Except for certain information that is required by law, your decision to provide any personal data to SetPlans LLC is voluntary. You will therefore not be subject to adverse consequences if you do not wish to provide SetPlans LLC with your personal data. However, please note that if you do not provide certain information, SetPlans LLC may not be able to accomplish some or all of the purposes outlined in this global privacy statement, and you may not be able to use certain tools and systems which require the use of such personal data. Why does SetPlans LLC process your personal data? SetPlans LLC may collect, use, transfer, disclose and otherwise process your personal data in the context of facilitating communication with you (including in case of emergencies), operating and managing SetPlans LLC’s business operations, complying with legal requirements, monitoring your use of SetPlans LLC’s systems, undertaking data analytics and recruitment. SetPlans LLC will not use your personal data for purposes that are incompatible with the purposes listed in this global privacy statement, unless it is required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so. On which legal basis does SetPlans LLC process your personal data? SetPlans LLC will not use your personal data for purposes that are incompatible with the purposes listed in this global privacy statement, unless it is required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so. SetPlans LLC processes your personal data for the purposes set out in this global privacy statement for one or more of the following reasons: (i) because SetPlans LLC is required to do so for compliance with a legal obligation to which it is subject, (ii) because such information is necessary for the performance of a contract to which you are a party, (iii) because the processing is necessary for the purposes of the legitimate interests pursued by SetPlans LLC or by a third party (as described in the last sentence of this paragraph), or (iv) where necessary in order to protect the vital interests of any person. SetPlans LLC has legitimate interests in collecting and processing personal data, for example: (1) to ensure that SetPlans LLC’s networks and information are secure, (2) to administer and generally conduct business and (3) to prevent fraud. In addition, SetPlans LLC may process your sensitive data and/or make automated decisions concerning you where permitted by applicable law and/or with your prior consent and for the purposes mentioned in this privacy statement. Who has access to your personal data? Access to your personal data within SetPlans LLC will be limited to those employees who have a need to know the information for the purposes described in this global privacy statement, which may include personnel in Security, HR, IT, Compliance, Legal, Finance and Accounting, Corporate Investigations and Internal Audit. All employees within SetPlans LLC will generally have access to your business contact information (e.g. name, position, telephone number and e-mail address). Furthermore, your personal data may be transferred to other SetPlans LLC offices and third parties, which may involve transferring your personal data to other countries. Furthermore, where there is a need, SetPlans LLC may share your personal data with third parties, such as service providers and public authorities. Before doing so, SetPlans LLC takes steps to protect your personal data. Any third party service providers and professional advisors to whom your personal data are disclosed, are expected and required to protect the confidentiality and security of your personal data and may only use your personal data in compliance with applicable data privacy laws. How does SetPlans LLC protect your personal data? SetPlans LLC maintains organizational, physical and technical security arrangements for all the personal data it holds. SetPlans LLC has protocols, controls and relevant policies, procedures and guidance to maintain these arrangements taking into account the risks associated with the categories of personal data and the processing SetPlans LLC undertakes. How long does SetPlans LLC retain your personal data? SetPlans LLC retains your personal data only for as long as is necessary. SetPlans LLC maintains specific records management and retention policies and procedures, so that personal data are deleted after a reasonable time according to the following retention criteria: • SetPlans LLC retains your personal data as long as it has an ongoing relationship with you. • SetPlans LLC retains your personal data for as long as needed in order to comply with a legal obligation to which it is subject. • SetPlans LLC retains your personal data where this is advisable to safeguard or improve SetPlans LLC’s legal position (for instance in relation to statutes of limitations, litigation, or regulatory investigations). Please keep your personal data at all times up to date and inform SetPlans LLC of any material changes to your personal data. Which rights do you have concerning your personal data? You have the right (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law to: • Request access to the personal data we process about you: This right entitles you to know whether SetPlans LLC holds personal data of you and, if so, obtain information on and a copy of those personal data. • Request rectification of your personal data: This right entitles you to have your personal data be corrected if it is inaccurate or incomplete. • Object to the processing of your personal data: This right entitles you to request that SetPlans LLC no longer processes your personal data. • Request the erasure of your personal data: This right entitles you to request the erasure of your personal data, including where such personal data would no longer be necessary to achieve the purposes. • Request the restriction of the processing of your personal data: This right entitles you to request that SetPlans LLC only processes your personal data in limited circumstances, including with your consent. • Request portability of your personal data: This right entitles you to receive a copy (in a structured, commonly used and machine-readable format) of personal data that you have provided to SetPlans LLC, or request SetPlans LLC to transmit such personal data to another data controller. Please note, however, that certain personal data may be exempt from the above-mentioned rights pursuant to applicable data privacy or other laws and regulations. If, despite SetPlans LLC’s commitment and efforts to protect your personal data, you believe that your data privacy rights have been violated, we encourage and welcome you to come to SetPlans LLC first to seek resolution of any complaint. You have the right at all times to register a complaint directly with the relevant supervisory authority or to make a claim against SetPlans LLC with a competent court (either in the country where you live, the country where you work or the country where you deem that data privacy law has been infringed). What if you have questions or want further information? This global privacy statement, and the web pages referred to therein, aims to give you complete and transparent information on how SetPlans LLC processes your personal data. If you have any further questions or concerns regarding how SetPlans LLC processes your personal data, or if you wish to exercise any of your foregoing rights, please visit our Contact page.