PRIVACY POLICY

This Privacy Policy governs the processing of your personal data by the GESENTA group of companies (referred to as: “GESENTA”, ,“GESENTA Tech”, "Castle Tech", "LvChuangYuan", "JinDeXiang", “Kiyinaga Tech”, “we”, “us”, “our”) captured through the following methods:

· when you visit our global and local websites (the “Website”);

· when you communicate with us via e-mail, telephone, fax and/or social media channels; and/or

· through other online and offline channels.

If you want more information on how we process personal data via cookies, social plugins and other types of tracking technology, please refer to our Cookie Policy.

1. IN GENERAL

1.1. You can contact us via e-mail at privacy@Gesenta.com.

1.2. A reference in this Privacy Policy to certain laws or regulations also includes any change, replacement or annulment of these laws or regulations, including any related executive decisions.

1.3. GESENTA reserves the right to from time to time modify, change or amend this Privacy Policy at its own discretion. Such modification, change or amendment will be communicated via the Website. If you do not accept the modifications, changes or amendments, you are not allowed to use our Website anymore.

2. TYPES OF PERSONAL DATA WE COLLECT

2.1. Whenever you use our Website and social media channels, we collect the following information in accordance with our Cookie Policy:

· Geolocation Information: this includes technical information associated with the device you use, such as your IP-address, browser type, geographical location and operating system; and

· Internet/Electronic Activity Information: this includes information concerning your browsing behaviour, such as how long you visit, what links you click on, what pages you visit and how many times you visit a page.

When using our Website and social media channels, you may do so anonymously or pseudonymously, except where you contact us as set out below.

2.2. When you fill out a contact form (either offline or via our Website), directly make a purchase with us, apply for a job, participate in promotions such as sweepstakes or contests, or contact us in person (such as at trade conferences) via e-mail, telephone, fax or social media channels, we collect:

· Identifier Information and/or Information Protected Against Security Breaches: this includes information you provide us with, such as name, e-mail address, postal address, phone number, mobile telephone number, your country, and the company you work for, and your billing information, including your address and credit card number, if you make purchases with us;

· Commercial Information: the content of your communication or enquiry and the technical details of the communication itself (with whom you correspond at our end, date, time, etc.), as well your preferences as to the communication medium used;

· Professional, Employment, or Education Related Information: this includes job application information, such as your education and work history, skills and qualifications for a particular position;

· Public Information: this includes publicly available information of your profile on social media channels;

· Other: any other personal data you choose to provide to us.

2.3. We receive all the personal data listed above directly from you. We may also receive additional information about your preferences and surfing behaviour from our partners, including our business and commercial partners– who collect your personal data from you when you interact with them. When dealing with such third parties, these third parties will process your personal data in accordance with their own privacy policy.

3. PURPOSES FOR WHICH GESENTA USES YOUR PERSONAL DATA

3.1. GESENTA processes your personal data to provide you in a personalized and efficient way the information, products and services you request via the Website, by e-mail, telephone, fax or social media channels.

3.2. GESENTA processes your personal data for marketing purposes, i.e. to provide you with targeted communications, promotions, offerings and other advertisements of GESENTA and selected partners.

3.3. Unless you are an existing customer who has already purchased similar goods or services from us and who we wish to target with our own marketing material, GESENTA will only send you communications, promotions, offerings, newsletters and other advertisements via e-mail or other person-to-person electronic communication channels that you have explicitly consented to receive.

3.4. GESENTA processes your personal data to comply with legal obligations or to comply with any reasonable request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities.

GESENTA may transfer your personal data to the police or the judicial authorities as evidence or if there are justified suspicions of an unlawful act or crime committed by you through your registration with or use of the Website, our social media channels or other communication with us.

3.5. GESENTA processes your personal data to perform statistical analyses so that we may improve our Website, advertisement, products and services or to develop new products and services.

3.6. GESENTA may process your personal data to preserve the legitimate interests of GESENTA, its partners or a third party if your registration with or use of the Website, social media channels or other communication channels can be considered:

(a) a violation of any applicable terms of use or the intellectual property rights or any other right of a third party;

(b) a threat to the security or integrity of the Website, social media channels or other communication channels;

(c) a danger to the Website, social media channels or other communication channels or any of GESENTA’s or its subcontractors’ underlying systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code; or

(d) in any way hateful, obscene, discriminating, racist slanderous, spiteful, hurtful or in some other way inappropriate or illegal.

4. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

4.1. The processing of your personal data for the purpose outlined in Article 3.3. above is based on your consent.

4.2. If your personal data is processed for the purpose outlined in Article 3.1. and in order to take steps prior to entering into a contract with us, we may process your personal data as necessary for the performance of that contract, or in the process of entering into that contract.

4.3. For the purpose mentioned in Article 3.4., the processing of your personal data is necessary for GESENTA’s legal obligations.

4.4. For the purposes mentioned in the Articles 3.1, 3.2, 3.5. and 3.6. above, the processing of your personal data is necessary for purposes of our legitimate interests, such as:

· continuous improvements of the GESENTA Website, social media channels, products and services to ensure that you have the best experience possible;

· keeping our Website, social media channels, products and services safe from misuse and illegal activity; and

· marketing and promotion of our products, services, brands and overall successful commercialization of our products and services.

5. TO WHOM GESENTA SENDS YOUR DATA

5.1. GESENTA relies on third party processors to provide you our Website and to process your personal data on our behalf for the purposes set out in Article 3 above. These third-party processors are only allowed to process your personal data on behalf of GESENTA upon explicit written instruction from us.

GESENTA warrants that all third-party processors are selected with due care and are obliged to observe the safety and integrity of your personal data.

5.2. GESENTA may share your personal data with other entities within the GESENTA group for the purposes of sales, marketing and financial data analysis. We will ensure that all GESENTA entities will take due care that all processing of your personal data is in line with this Privacy Policy.

5.3. GESENTA may publicly disclose your personal data in cases of law, legal proceedings, litigation or mandatory requirements of the competent government authorities.

5.4. GESENTA does not send your personal data in an identifiable manner to any third party other than those mentioned in Articles 5.1., 5.2 and 5.3, without your explicit permission to do so. GESENTA may send anonymized data to other organizations that may use such data for improving products and services as well as for the purposes of tailoring the marketing, displaying and selling of those goods and services.

5.5. When it comes to mergers, acquisitions or bankruptcy liquidation, GESENTA will require new companies and organizations that hold your personal data to continue to be bound by this Privacy Policy, otherwise we will ask the companies and organizations to re-seek consent from you.

6. LOCATION, TRANSFER AND STORAGE

6.1. GESENTA may need to transfer your personal data to other GESENTA entities or third parties who process personal data on our behalf to locations outside the jurisdiction in which you provided it.

If you are based within the European Economic Area (“EEA”), please note that where necessary to provide the products and services, we may transfer personal data to GESENTA entities located in countries outside of the EEA. All GESENTA entities have signed a data transfer agreement which is based on EU standard contractual clauses to ensure we comply with our legal and regulatory obligations in relation to personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for personal data.

6.2. GESENTA may transfer anonymized and/or aggregated data to organizations outside the jurisdiction in which you provide it. Should such transfer take place, GESENTA will ensure that there are safeguards in place to ensure the safety and integrity of your data and all rights with respect to your personal data you might enjoy under applicable mandatory law.

6.3. GESENTA holds your personal data both electronically and/or in hard copy form. We may store your information on our own premises or the premises of our third-party processors or other service providers. We will protect personal data we keep in accordance with Article 7.4 below.

7. QUALITY ASSURANCES

7.1. GESENTA does its utmost best to process only those personal data which are necessary to achieve the purposes listed under Article 3 above.

7.2. Your personal data is only processed for as long as needed to achieve the purposes listed under Article 3 above or up until such time where you withdraw your consent. Withdrawing your consent may mean that you can no longer use all or part of our Website. GESENTA will de-identify your personal data when it is no longer necessary for the purposes outlined in Article 3 above, unless there is:

· an overriding interest of GESENTA, or any other third party, in keeping the personal data identifiable; and/or

· a legal or regulatory obligation or a judicial or administrative order that prevents GESENTA from de-identifying them.

7.3. You understand that an essential aspect of our marketing efforts is about making our marketing materials more relevant to you. GESENTA does this by:

· customising your unique profile based on relevant characteristics as outlined in Article 2 of this Privacy Policy; and

· using this profile to provide you with communications, promotions, offerings, newsletters and other advertisements about products and services that may interest you.

7.4. GESENTA will take appropriate technical and organizational measures to keep your personal data safe from unauthorized access or theft as well as accidental loss tampering or destruction. Access by GESENTA personnel or its third-party processors will only be on a need-to-know basis and be subject to strict confidentiality obligations. Please understand, however, that safety and security are best effort obligations which can never be guaranteed.

7.5. If you are registered to receive communications, promotions, offerings, newsletters and other advertisements via e-mail or other person-to-person electronic communication channels, you can change your preferences for receiving such communications, promotions, offerings, newsletter and other advertisements by following the opt-out link provided in such communications.

8. YOUR RIGHTS

8.1. You have the right to request access to all of your personal data processed by GESENTA. Each request must specify: (a) which processing activity you wish to exercise your right to access and (b) which data categories you wish to gain access to. GESENTA reserves the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to GESENTA.

8.2. You have the right to ask that any inaccuracies in your personal data held by GESENTA be corrected free of charge. If you submit a request for correction, your request needs to be accompanied by proof of the inaccuracy.

8.3. You have the right to withdraw your earlier consent for the processing of your personal data.

8.4. You have the right to request that your personal data is deleted if such data is no longer required for the purposes set out in Article 3 above or if you withdraw your consent for its processing. However, please keep in mind that a request for deletion will be evaluated by GESENTA against:

· the overriding interests of GESENTA or any other third party; and

· legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.

Instead of deletion, you can also ask that GESENTA limit the processing of your personal data if (a) you contest the accuracy of the data, (b) the processing is illegitimate, or (c) the data is no longer needed for the purposes listed under Article 3 above.

8.5. You have the right to oppose the processing of personal data if you prove that there are serious and justified reasons that warrant such opposition. However, if the intended processing qualifies as direct marketing, you have the right to oppose such processing free of charge and without justification.

8.6. You have the right to receive from us in a structured, commonly-used and machine-readable format all personal data you have provided to us.

8.7. If GESENTA sells your personal data to third parties, you have the right, at any time, to direct us not to sell your personal data. GESENTA does not sell personal data.

8.8. You have the right to be free from discrimination or retaliation for exercising any of your rights as described above.

9. HOW TO EXERCISE YOUR RIGHTS

9.1. If you wish to submit a request to exercise one or more of the rights listed above, you can do so using one of the following methods:

· Send an e-mail to privacy@Gesenta.com. Please note that an e-mail requesting to exercise a right will not be taken as a consent to process your personal data beyond what is required for handling your request.

· Call us: +86-22-2854-9857

All requests submitted through any of these methods should:

· clearly state which right you wish to exercise and the reasons for it, if required;

· be dated and signed; and

· be accompanied by a digitally scanned copy of your valid identity card proving your identity. If you contact us via phone, GESENTA may ask you for your signed confirmation and proof of identity.

GESENTA will promptly inform you when we receive your request. If the request is valid, GESENTA shall honour it as soon as reasonably possible and at the latest thirty (30) days after having received the request.

If you have any complaint regarding the processing of your personal data by GESENTA, you may contact us through any of the methods listed above. If you remain unsatisfied with our response, you may file a complaint with the relevant regulator or data protection authority in your country.

9.2. In order to comply with certain requirements of relevant laws and regulations, GESENTA will not be able to respond to your request in circumstances:

a. that directly relate to national security and national defense security;

b. that directly relate to public safety, public health and major public interests;

c. that directly relate to criminal investigations, prosecutions, trials and execution of judgments.

d. where there is ample evidence that you have subjective malice or abuse of rights.

e. where, in response to your request, you will cause serious damage to the legitimate rights and interests of you or other individuals and organizations; or

f. that involve business secrets.

TERMS OF USE

Carefully read these Terms of Use before using this Website. By using the Website, you accept and agree to be bound and abide by these Terms of Use . If you do not accept these terms, do not use this Website.

The GESENTA group of companies (collectively referred to as “GESENTA”) reserves the right to change these Terms of Use from time to time without notifying you. If you object to any such changes, your sole recourse shall be to cease using this Website. Continued use of the Website following the effective date any such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms of such changes.

GESENTA takes the privacy of our customers very seriously and wants you to feel comfortable whenever you visit our Website, access our online services, or participate in our online offerings. For more information, please visit GESENTA’s Privacy Policy.

INTELLECTUAL PROPERTY AND USAGE OF CONTENT

The Website and its entire contents, features, and functionality (including but not limited to all information, software, text, displays, images, video, and audio, and the design, selection, and arrangement thereof) are owned by GESENTA and third party licensors and are protected by international copyright, trademark, patent, trade secret, and other intellectual property or proprietary rights laws. You are authorized to view, download and reproduce the materials at this Website only for your personal or non-commercial use provided that you 1) retain all notices contained in the original materials 2) only use images with surrounding text relating to the images, and 3) include the following copyright notice:

No further publication or commercial use may be made of the materials on this Website without the express written permission of GESENTA. Except as expressly provided, nothing contained in this Terms of Use shall be construed as conferring any license or right under any GESENTA copyright.

You may not make any part of this Website available as part of another web site whether by hyperlink framing on the internet or otherwise. This Website and its content may not be used to construct a database of any kind nor may the same be stored (in whole or part) in databases for access by you or any third party or to distribute any database containing all or part of the Website or its content.

You may not use any deep-link, page-scrape, spider, robot, crawl, index, Internet agent or other automatic device, program, algorithm or technology which does the same things, to use, access, copy, acquire information, generate impressions, input information, store information, search, generate searches or monitor any portion of this website.

TRADEMARKS

GESENTA, the GESENTA logo, and most other brand or product names, designs, and logos on this Website are among the trademarks and/or service marks of GESENTA. Trademarks of other parties are identified wherever possible and GESENTA acknowledges their rights. Further, any product, process or technology described in the materials on this Website may be the subject of other intellectual property rights reserved by GESENTA and are not licensed hereunder.

OTHER TERMS AND NOTICES MAY APPLY

Additional terms and conditions will apply to business transactions conducted or any promotions run by GESENTA via this Website. Additional terms will govern any bulletin board services, chat areas and or other message or communication facilities offered via this Website. Nothing contained in this page is intended to modify or amend any agreement currently in effect between you and GESENTA.

Although these terms of use are intended to apply generally to all content located under GESENTA.com, this Website may contain other proprietary notices and conditions of use, the terms of which must also be observed and followed as they apply to the particular portions of this Website for which they are intended. Certain portions of this Website are intended for audiences in specific countries as indicated by specific country references in the website page header information. Terms of use for country specific website pages may vary and can be accessed from the GESENTA website for that specific country. GESENTA may revoke or modify any of the rights stated in this Legal Information Page at any time by updating this page.

DISCLAIMERS

The information contained in this website is provided to you “as is,” for your internal informational purposes only, without any representation or warranty of accuracy or completeness of quality, merchantability, fitness for a particular purpose, or non-infringement.In no event will GESENTA be liable to any party for any direct,indirect,incidental,special or consequential damages for use of the website or reliance upon any information or material accessed via it or any other hyperlinked website including,but not limited to,damages arising from loss of profits, business interruption, or loss of data, even if GESENTA is expressly advised about the possibility of such damages, to the fullest extent allowable by low.Some jurisdictions do not allow the exclusion or implied warranties and representations, so the above exclusions may not apply to you.

The material on this Website could contain technical inaccuracies or typographical errors, and information will be changed, updated and deleted without notice. GESENTA may make improvements and/or changes in the products, services and/or the programs described in this material at any time. GESENTA makes no warranties that this Website will operate uninterrupted or error free or that defects will be corrected. GESENTA does not warrant that this Website is compatible with your computer equipment or that this Website or its server is free of errors or viruses, worms or "Trojan horses" and GESENTA is not liable for any damage you may suffer as a result of such destructive features. The products of GESENTA referred to on this Website may not be available for sale in all countries. No representation is made by GESENTA as to the availability of a particular product in a particular country.

Additionally, GESENTA makes no representations or warranties whatsoever about any other Website which you may choose to access through this Website. Links provided by GESENTA to such Websites are provided solely for your convenience and should not be deemed to imply that GESENTA endorses those Websites or any content therein.

This Website (excluding linked sites) is controlled by GESENTA Limited from its offices in Tianjin, China. It can be accessed from China, as well as from other countries around the world. As each of these places have laws that may differ from those of Australia, by accessing this Website both you and GESENTA agree that the statutes and laws of the city of Tianjin, China, without regard to conflicts of law principles thereof, will apply to all matters relating to this Website. You also agree and hereby submit to the exclusive jurisdiction and venue of the courts of Tianjin, China with respect to such matters. GESENTA makes no representation that materials on the Website are appropriate or available for use in other locations, and accessing them from territories where their contents are illegal is prohibited. Those who choose to access this Website from other locations do so on their own initiative and are responsible for compliance with local laws.

SUBMITTING INFORMATION TO GESENTA

Any information that GESENTA receives through its Website, other than your personally identifiable information covered by GESENTA's Privacy Policy, will be deemed to be NON-CONFIDENTIAL AND NON-PROPRIETARY. BY TRANSMITTING TO GESENTA INFORMATION VIA THIS WEBSITE OR OTHERWISE THROUGH ELECTRONIC MEANS WITHOUT A WRITTEN AGREEMENT WITH GESENTA RELATING TO YOUR SUBMISSION. YOU UNDERSTAND AND AGREE THAT GESENTA MAY USE THAT INFORMATION FOR ANY PURPOSE WHATSOEVER WITHOUT OBLIGATION TO YOU. You may not use Website for any purpose that is unlawful or prohibited by these Terms of Use, or to solicit the performance of any illegal activity or other activity which infringes the rights of GESENTA or others.

7.3COOKIES POLICY (仅有英文版）

COOKIE POLICY

This Cookie Policy governs the use of cookies and social media plugins by the GESENTA group of companies (hereinafter: “GESENTA”, “we”, “us”, “our”) as part of your visit to our global and local websites (hereinafter: “Website”).

Cookies are small text files which are stored on a device’s hard drive and which contain certain information and sometimes personal data. Social media plugins are small pieces of software developed and provided by social media service providers, which add social media integration when built into the Website.

If you want general information about how we process your personal data other than through cookies and social media plugins, including in relation to your communication with us via e-mail, phone, fax and social media and in relation to any order or purchase, please see our Privacy Policy.

By continuing to use the Website after having been informed of the use of cookies and you acknowledge that you have read and accept this Cookie Policy.

1. IN GENERAL

1.1. Your personal data are processed by GESENTA. You can contact us via e-mail at privacy@gesenta.com

1.2. A reference in this Cookie Policy to certain laws or regulations also includes any change, replacement or annulment of these laws or regulations, including any related executive decisions.

1.3. GESENTA reserves the right to from time to time modify, change or amend this Cookie Policy at its own discretion. Such modification, change or amendment will be communicated via the Website. If you do not accept the modifications, changes or amendments, you are not allowed to use our Website anymore.

2. COOKIES

2.1.You can avoid cookies being placed by configuring your browser as such. Guidelines about how to do this can be found here:

· Internet Explorer

· Chrome

· Safari

However, not allowing cookies when visiting the Website may cause certain or all features of the Website to stop working properly.

2.2. When you visit the Website, GESENTA places a number of cookies. Most data pertaining to these cookies, their placement and use allow to identify you, and GESENTA uses them to gain insight in how you and other visitors use the Website by gathering statistical and usage data, enabling GESENTA to provide a better user experience on the Website.

2.3. GESENTA knows about the following cookies being used on the Website:

Name	Type	Purpose	Storage period
“_mrkto_trk”	Analytical and statistical	We use Marketo Munchkin tracking cookies to determine how you and other visitors use our Website. With these insights we are able to compile reports, take actions and improve our services. These cookies collect information in an anonymous and known form depending on if that individual has provided us their details before.It tracks what pages an individual visits, links they click on and forms they fill out.	Activities are stored for 90 days. (Page visits are clicks) Provided data form fills are stored for 2 years
Name	Type	Purpose	Storage period
Google Analytics cookies, including: · “_gat”, · “_ga”, · “_gid”,	Analytical and statistical	We use Google Analytics cookies to determine how you and other visitors use our Website. With these insights we are able to compile reports and improve our Website and services. These cookies collect information in an anonymous form, including the number of visitors to the Website, where visitors have come to the site from and the pages they visited.	“_gat”: 10 minutes “_ga”: 2 years “_gid”: 1 da

2.4. You may at all times withdraw your consent with our use of cookies. To exercise this right, it suffices to delete the cookies, which have been placed on your device. To do so, you are kindly asked to refer to the appropriate instructions of your browser manufacturer, as listed above.

3. PURPOSES FOR WHICH GSENTA USES YOUR PERSONAL DATA

3.1. GESENTA processes your personal data to perform statistical analyses so that we may improve our Website, advertisement, products and services or to develop new products and services.

3.2. GESENTA may also process your personal data for the preservation of the legitimate interests of GESENTA, its affiliates and partners or a third party if your registration with or use of the Website can be considered (a) a violation of this Cookie Policy or the intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of any of the Website or to GESENTA or to any of its affiliates’ or its subcontractors’ underlying systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code, or (c) in any way hateful, obscene, discriminating, racist slanderous, spiteful, hurtful or in some other way inappropriate or illegal.

3.3. Your personal data may be transferred to the police or the judicial authorities as evidence or if there are justified suspicions of an unlawful act or crime committed by you through your use of any of the Website.

4. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

4.1. The processing of your personal data for the purposes outlined in Article 3 above is based on your consent or a legal obligation that GESENTA must comply with.

4.2. In some cases, the processing of your personal data may be necessary for purposes of our legitimate interests, such as:

· Continuous improvements of the GESENTA Website, social media channels, products and services to ensure that you have the best experience possible;

· Keeping our Website, social media channels, products and services safe from misuse and illegal activity;

· Marketing and promotion of our products, services, brands and overall successful commercialization of our products and services.

5. TO WHOM GESENTA SENDS YOUR DATA

5.1. GESENTA relies on third-party processors to provide you our Website and to process your personal data on our behalf. These third-party processors are only allowed to process your personal data on behalf of GESENTA upon explicit written instruction of GESENTA.

GESENTA warrants that all third-party processors are selected with due care and are obliged to observe the safety and integrity of your personal data.

5.2. GESENTA may share your personal data with other entities within the GESENTA group. However, we will ensure that all GESENTA entities will take due care that all processing of your personal data is in line with what is set out in this Cookie Policy.

5.3. GESENTA may publicly disclose your personal data in cases of law, legal proceedings, litigation or mandatory requirements of the competent government authorities.

5.4. GESENTA does not send your personal data in an identifiable manner to any other third party than the ones mentioned in Articles 5.1. 5.2 and 5.3. without your explicit permission to do so. However, GESENTA may send anonymized data to other organizations that may use those data for improving products and services as well as to tailor the marketing, displaying and selling of those goods and services.

5.5. When it comes to mergers, acquisitions or bankruptcy liquidation, GESENTA will require new companies and organizations that hold your personal data to continue to be bound by this privacy policy, otherwise we will ask the companies and organizations to re-seek authorization from you.

6. LOCATION AND TRANSFER

6.1. GESENTA may need to transfer your personal data to other GESENTA entities or third parties who process personal data on our behalf in locations outside the jurisdiction in which you provide it.

7. QUALITY ASSURANCES

7.1. GESENTA does its utmost best to process only those personal data which are necessary to achieve the purposes listed under Article 3 above.

7.2. Your personal data are only processed for as long as needed to achieve the purposes listed under Article 3 above or up until such time where you withdraw your consent for processing them. Your withdrawal of consent may imply that you can no longer use the whole or part of our Website. GESENTA will de-identify your personal data when they are no longer necessary for the purposes outlined in Article 3 above, unless there is:

· An overriding interest of GESENTA , or any other third party, in keeping our personal data identifiable;

· A legal or regulatory obligation or a judicial or administrative order that prevents GESENTA from de-identifying them.

7.3. GESENTA will take appropriate technical and organizational measures to keep your personal data safe from unauthorized access or theft as well as accidental loss tampering or destruction. Access by personnel of GESENTA or its third party processors will only be on a need-to-know basis and be subject to strict confidentiality obligations. You understand, however, that safety and security are best efforts obligations which can never be guaranteed.

8. YOUR RIGHTS

8.1. You have the right to request access to all personal data processed by GESENTA pertaining to you. GESENTA reserves the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to GESENTA . Each request must specify for which processing activity you wish to exercise your right to access and must specify to which data categories you wish to gain access to.

8.2. You have the right to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. If you submit a request for correction, your request needs to be accompanied of proof of the flawed nature of the data for which correction is asked.

8.3. You have the right to withdraw your earlier given consent for processing of your personal data.

8.4. You have the right to request that personal data pertaining to you be deleted if these data are no longer required in the light of the purposes outlined in Article 3 above or if you withdraw your consent for processing them. However, you need to keep in mind that a request for deletion will be evaluated by GESENTA against:

· Overriding interests of GESENTA or any other third party;

· Legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.

Instead of deletion you can also ask that GESENTA limits the processing of your personal data if (a) you contest the accuracy of the data, (b) the processing is illegitimate, or (c) the data are no longer needed for the purposes listed under Article 3 above.

8.5. You have the right to oppose the processing of personal data if you are able to prove that there are serious and justified reasons connected with this particular circumstance that warrant such opposition. However, if the intended processing qualifies as direct marketing, you have the right to oppose such processing free of charge and without justification.

8.6. You have the right to receive from us in a structured, commonly-used and machine-readable format all personal data you have provided to us.

8.7. If you wish to submit a request to exercise one or more of the rights listed above, you can send an e-mail to privacy@gesenta.com. An e-mail requesting to exercise a right will not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request should clearly state which right you wish to exercise and the reasons for it if such is required. It should also be dated and signed, and accompanied by a digitally scanned copy of your valid identity card proving your identity. If you use the contact form, GESENTA may ask you for your signed confirmation and proof of identity.

GESENTA will promptly inform you of having received this request. If the request proves valid, GESENTA shall honour it as soon as reasonably possible and at the latest thirty (30) days after having received the request.

If you have any complaint regarding the processing of your personal data by GESENTA , you may always contact GESENTA via the e-mail address listed above. If you remain unsatisfied with our response, you are free to file a complaint with the competent data protection authority.

8.8. In the following circumstances, GESENTA will not be able to respond to your request in accordance with the requirements of relevant laws and regulations:

a. directly related to national security and national defense security;

b. directly related to public safety, public health and major public interests;

c. directly related to criminal investigation, prosecution, trial and execution of judgments.

d. there is ample evidence that you have subjective malice or abuse of rights.

e. in response to your request, you will cause serious damage to the legitimate rights and interests of you or other individuals and organizations.

f. involving business secrets