Privacy Statement & Cookie Policy Last edited: June 17, 2024 Published on: June 18, 2024

PRIVACY STATEMENT & COOKIE POLICY

Authority: Management Board
Approved by: Maurits Leenaers
Responsible: Legal/Compliance Department

Employees Concerned: All Employees

Departments Concerned:

• Human Resources
• Sales Trading
• Legal and Compliance
• IT

Version History: V1
Created: June 2024
Effective Date: June 2024
Reviewed and Modified: June 2024

Privacy Statement

1. Introduction

1.1. This document is the Privacy Statement for Amsterdam Renewable Markets B.V., based in Amsterdam, the Netherlands (“Amsterdam Renewable Markets”). It outlines our procedures for handling personal data with the highest level of care. Amsterdam Renewable Markets is the data controller for the processing of personal data as described in this statement.

1.2. If you have any questions about our handling of your personal data after reviewing this Privacy Statement, or if you wish to exercise your rights under the General Data Protection Regulation (“GDPR”) or other relevant data protection laws, or if you wish to file a complaint regarding our use of your personal data, please contact us at legal@amsterdamrenewablemarkets.com. Additional information can be found on the Dutch Data Protection Authority’s website: Autoriteit Persoonsgegevens.

1.3. Our contact details are:

Amsterdam Renewable Markets B.V.
Warmoesstraat 151, 3^e voor
1012 JC Amsterdam
legal@amsterdamrenewablemarkets.com

2. Personal Data of Counterparty Contacts

2.1. Processed Data, Purpose, and Legal Basis

2.1.1. We collect and process the contact details (name, company name, phone number, email) of individuals at our counterparties. The legal basis for this processing is that it is necessary to enter into and perform contracts with counterparties.

2.1.2. We record conversations in our company with contacts at counterparties to document trades and enhance our services. This processing is based on Amsterdam Renewable Markets’ legitimate interest in confirming transaction details and ensuring transparency in communications with counterparties.

2.1.3. We also utilize the contact details of counterparties for relationship management purposes. This processing is grounded in Amsterdam Renewable Markets’ legitimate interest in maintaining strong relationships with counterparties.

2.2. Retention Period for Personal Data

2.2.1. We retain personal data of counterparty contacts for seven years following the completion of the last transaction with the counterparty. Our administrative records, including invoices and other documents containing personal data, are kept for seven years after the end of the fiscal year to comply with statutory tax retention requirements.

2.2.2. Recordings of trading room conversations are kept for five years. Extensions up to seven years may occur if regulatory authorities conduct complex investigations during their supervisory activities.

3. Personal Data in the Context of the CEE Scheme

3.1. We process personal data of individuals involved in the French dispositif des Certificats d’économies d’énergie (CEE), in accordance with French law (Loi 2005-781 du 13 Juillet 2005), when submitting CEE files to the (EMMY) register. This processing is justified by our legitimate interest in conducting our business activities, and also by the consent obtained from each involved individual.

3.2. Personal data related to the French dispositif des CEE is retained for nine years following the submission of a file to the competent authority, as mandated by French law.

4. Personal Data of Prospective and Former Counterparties

4.1. We process the contact details (name, company name, telephone number, email) of prospective and former counterparty contacts to offer our services and send holiday greetings. This processing is based on our legitimate interest in business development.

4.2. The personal data of prospective counterparties is deleted upon request of the data subject or two years after the final communication, whichever occurs first.

5. Personal Data of Individuals Contacting Amsterdam Renewable Markets

5.1. When individuals contact us through our website, email, social media, or telephone, we process the provided data, typically including name, email, telephone number, and the content of the communication. We use this information to respond to inquiries and may add it to our files. This processing is based on our legitimate interest in delivering high-quality and efficient commercial support services.

6. Personal Data in Recruitment and Application Processes

6.1. We process personal data provided by job applicants or obtained from recruitment agencies, LinkedIn, and other online job boards. This may include name, address, email, telephone number, CV, and information contained within the CV. If an applicant is invited for an interview, we process additional information provided during the interview, such as education, work experience, and references.

6.2. The legal basis for processing personal data in recruitment is that it is necessary to take steps at the request of the data subject prior to entering into an employment contract, and based on Amsterdam Renewable Markets’ legitimate interest in conducting recruitment activities and hiring staff.

6.3. Information about unsuccessful applicants is deleted immediately after the application process unless the candidate consents to us retaining their details for one year after the application process concludes. This retention period allows us to evaluate applications, maintain a talent pool, and potentially contact applicants about future opportunities. Applicants can exercise their rights as described in Section 11 at any time.

7. Personal Data of Website Visitors

7.1. We process information about visitors to our website by placing cookies each time they visit. The legal basis for this processing is the consent obtained from visitors upon their first visit. Consent can be withdrawn at any time. For more details, please refer to our cookie policy below.

8. Retention of Other Contact Details

We retain other contact details for one year after the final contact or until a deletion request is submitted.

9. Data Sharing

Personal data is stored electronically and may be included in emails we send or receive. This data is stored and processed by our IT provider. We may enter into data processing agreements with these providers to ensure a high level of security and reliability.

Our accountant, auditors, and supervisory authorities may have access to personal data of counterparty contacts.

We may also share personal data of counterparty contacts with third parties when necessary to provide our services or as required by law or regulatory authorities. This includes sharing data with sellers, buyers, trading venues, the Pôle National des Certificats d’Economies d’Energie, the obligé within the CEE scheme, or any national authority related to the specific products we trade.

Cookie data is processed by the providers of those cookies. For more details, please see our cookie statement.

Apart from these scenarios, we do not share personal data with third parties unless required by applicable laws or regulations, such as providing data to the police under a warrant.

10. Security Measures

We maintain a stringent security policy, incorporating appropriate technical and organizational measures to protect personal data against loss, misuse, and unauthorized access. We enforce strict access controls both offline and online, regularly back up our servers, and ensure secure connections. Our servers are located in the Netherlands.

11. Your Rights

You have the following rights regarding your personal data:

11.1. The right to access your personal data and receive a copy.

11.2. The right to rectify inaccurate or incomplete personal data.

11.3. The right to object to and/or restrict the processing of your personal data in certain circumstances.

11.4. The right to have your personal data erased ("right to be forgotten") in certain circumstances.

11.5. The right to receive your personal data in a structured, commonly used, and machine-readable format.

11.6. The right to lodge a complaint with a supervisory authority (Autoriteit Persoonsgegevens in the Netherlands).

11.7. For more information on these rights and when you can exercise them, please refer to Articles 15 to 20 of the GDPR.

11.8. You may exercise your rights by contacting us using the email or telephone number provided at the beginning of this Privacy Statement.

12. Changes to the Privacy Statement

12.1. We may amend this Privacy Statement when changes occur in the personal data we process or in applicable legislation.

Cookies Policy

13.1. This policy explains the use of cookies on our website. It may be updated periodically. By using our website, you consent to the placement of cookies on your device as outlined in this Cookie Policy. If you do not wish to accept cookies, please disable them or refrain from using our site.

13.2. In this policy, "cookies" refers to cookies and similar technologies as defined by the EU Directive on privacy in electronic communications.

13.3. What is a cookie?

13.3.1. A cookie is a small data file that a website asks your browser to store on your computer or mobile device. It allows the website to remember your actions or preferences over time. Most internet browsers support cookies, but users can set their browsers to decline certain types of cookies or specific cookies. Users can also delete cookies at any time.

13.4. Why do we use cookies?

13.4.1. We use cookies to understand how you interact with our content and improve your experience on our website(s). For example, some cookies remember your language or preferences so you do not have to set these each time you visit our sites. We may use insights from your behavior on our site(s) for statistical and evaluation purposes.

13.5. Types of cookies we use

13.5.1. Essential cookies: We use cookies from the amsterdamrenewablemarkets.com domain to identify language and location preferences or provide basic site functionality.

13.6. How cookies are used

Cookies help us collect aggregated audit data and research. We do not provide any personal information collected through cookies to advertisers.

13.7. How to Reject and Delete Cookies

You can manage your cookie preferences for our website by adjusting your browser settings. Most browsers automatically accept cookies, so if you prefer not to use cookies, you may need to manually delete or block them. If you choose to reject cookies, you can still visit our website, although some functions may not operate properly. For more detailed information on how to delete or reject cookies, you can visit www.allaboutcookies.org. By using our website without deleting or rejecting some or all cookies, you consent to us placing those cookies that you have not deleted or rejected on your device.