Data Protection Policy

Introduction

Ab Ovo is a leading provider of sustainable IT solutions reducing the carbon footprint by optimizing the resources usage and digitizing the business processes. With a focus on delivering innovative solutions, Ab Ovo empowers organizations to digitize and optimize their processes, enhance visibility, and improve overall operational efficiency.

The personal data that we process to provide these services relates to our staff, suppliers’ staff (names, job titles, email addresses and phone numbers), clients’ staff (names, job titles email addresses and phone numbers) and other individuals as necessary.

This policy sets out our commitment to ensuring that the processing and storage of any personal data we process, is carried out in compliance with data protection law. We are committed to ensuring that all the personal data that we process is done by data protection law. Data Protection Law includes the General Data Protection Regulation 2016/679, the UK Data Protection Act 2018 and all relevant EU and UK data protection legislation. We ensure that good data protection practice is embedded in the culture of our staff and our organization.

Our other data protection policies and procedures are:

• record of processing activities
• privacy notices (website, clients, employees)
• personal data breach reporting process and a breach register
• data retention policy
• data subject rights procedure
• data protection impact assessment process
• IT security policies

Scope

This policy applies to all personal data processed by us and is part of our approach to compliance with data protection law. All of our staff are expected to comply with this policy and failure to comply may lead to disciplinary action for misconduct, including dismissal.

Data Protection Principles

We comply with the data protection principles set out below. When processing personal data, we make every effort to ensure that:

• it is processed lawfully, fairly and in a transparent manner about the data subject (“lawfulness, fairness and transparency”)
• it is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (“purpose limitation”)
• it is all adequate, relevant and limited to what is necessary about the purposes for which it is processed (“data minimization”)
• it is all accurate and, where necessary, kept up to date and that reasonable steps will be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased or rectified without delay (“accuracy”)
• it is kept in a form that permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed (“storage limitation”)
• it is processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction, or damage, using appropriate technical or organizational measures (“integrity and confidentiality”

We will facilitate any request from a data subject who wishes to exercise their rights under data protection law as appropriate, always communicating in a concise, transparent, intelligible and easily accessible form and without undue delay.

Process/Procedures/Guidance

We will:

• ensure that the legal basis for processing personal data is identified in advance and that all processing complies with the law, and document the decisions taken
• not do anything with data that one would not expect given the content of this policy and the fair processing or privacy notice
• ensure that appropriate privacy notices are in place advising staff and others how and why their data is being processed, and, in particular, advising data subjects of their rights where appropriate
• only collect and process the personal data that it needs for purposes it has identified in advance
• ensure that, as far as possible, the personal data it holds is accurate, or a system is in place to ensure that it is kept up to date as far as possible
• only hold onto personal data for as long as it is needed, after which time we will securely erase or delete the personal data – our data retention policy sets out the appropriate period
• ensure that appropriate security measures are in place to ensure that personal data can only be accessed by those who need to access it and that it is held and transferred securely

We will ensure that all staff including those of our suppliers who handle personal data on our behalf are aware of their responsibilities under this policy and other relevant data protection and information security policies, and that they are adequately trained and supervised.

Breaching this policy may result in disciplinary action for misconduct, including dismissal. Obtaining (including accessing) or disclosing personal data in breach of our data protection policies may also be a criminal offense.

Data Subject Rights

We have processes in place to ensure that we can facilitate any request made by an individual to exercise their rights under data protection law. All staff have received training and are aware of the rights of data subjects. Staff can identify such a request and know who to send it to.

All requests will be considered without undue delay and within one month of receipt as far as possible.

Subject access: the right to request information about how personal data is being processed, including whether personal data is being processed and the right to be allowed access to that data and to be provided with a copy of that data along with the right to obtain the following information:

• the purpose of the processing
• the categories of personal data
• the recipients to whom data has been disclosed or which will be disclosed
• the retention period
• the right to complain with the Information Commissioner’s Office
• the source of the information if not collected directly from the subject, and
• the existence of any automated decision-making

Rectification: the right to allow a data subject to rectify inaccurate personal data concerning them.

Erasure: the right to have data erased and to have confirmation of erasure, but only where:

• the data is no longer necessary about the purpose for which it was collected, or
• where consent is withdrawn, or
• where there is no legal basis for the processing, or
• there is a legal obligation to delete data

Restriction of processing: the right to ask for certain processing to be restricted in the following circumstances:

• if the accuracy of the personal data is being contested, or
• if our processing is unlawful but the data subject does not want it erased, or
• if the data is no longer needed for the processing but is required by the data subject for the establishment, exercise, or defense of legal claims, or
• if the data subject has objected to the processing, pending verification of that objection

Data portability: the right to receive a copy of personal data which has been provided by the data subject and which is processed by automated means in a format that will allow the individual to transfer the data to another data controller. This would only apply if we are processing the data using consent or based on a contract.

Object to processing: the right to object to the processing of personal data relying on the legitimate interests processing condition unless we can demonstrate compelling legitimate grounds for the processing which override the interests of the data subject or for the establishment, exercise, or defense of legal claims.

Special Category Personal Data

This includes the following personal data revealing:

• racial or ethnic origin
• political opinions
• religious or philosophical beliefs
• trade union membership
• the processing of genetic data, and biometric data to uniquely identify a natural person
• an individual’s health
• a natural person’s sex life or sexual orientation
• criminal convictions or offenses

We process special category data about our employees as necessary to comply with employment and social security laws. We do not process any special category data relating to clients, suppliers, third parties, or any of our data subjects except our employees.

This policy sets out the safeguards we believe are appropriate to ensure that we comply with the data protection principles set out above. We also have a data retention policy that sets out how long special category data will be held onto.

Responsibility for the Processing of Personal Data

If you have any concerns or wish to exercise any of your rights under the GDPR, then you can contact or make a subject access request to the data protection lead in the following ways:

• Name: Alex de Ruiter
• Address: Barbizonlaan 87, 2908 ME Capelle aan den IJssel – The Netherlands
• Email: alex.deruiter@abovo.com
• Telephone: +31 (0)10 286 1533
• Monitoring and Review
• This policy was last updated on January 15, 2024 and shall be regularly monitored and reviewed, at least every two years.

Glossary of Terms

Data Subject

An individual who is the subject of personal data or sensitive personal data.

Data Controller

An organization (either alone or jointly or in common with others) determines the purposes for which and how any personal data or sensitive personal data is to be processed.

Data Processor

Any person or organization who processes personal data on behalf of the data controller but is not employed by them. In our case, Data Processors include but are not limited to suppliers of Tele Marketing services.

Third-Party

Personal data or sensitive personal data, refers to any person other than the data subject, the data controller, or any data processor or other person authorized to process data for the data controller or processor. For example, the Police or HMRC.

Processing

Recording or holding data or carrying out any operations on that data including organizing, altering, or adapting it; disclosing the data or aligning, combining, blocking, or erasing it.

Data Breach

A failure leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data or sensitive personal data.

Subject Access Request

A written, signed request (which includes email and other written formats) from an individual to see data we hold about them. The Data Controller must provide all such information in a readable form within 1 month of receipt of the request.