1 INTRODUCTORY PROVISIONS

AXELOR SE, identification number 21986304, with its registered office at Nové sady 988/2, Staré Brno, 602 00 Brno, a company registered in the Commercial Register under file number H 2692 with the Municipal Court in Prague, issues this document as a personal data controller for the purpose of informing data subjects about relevant information related to the processing of their personal data and informing data subjects about their rights in relation to the processing of personal data.

The processing of personal data is governed primarily by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC and Act No. 110/2019 Coll., on the processing of personal data, as amended.

Unless otherwise stated below and/or unless the context otherwise requires, the following capitalized terms used later in this document have the following meanings:

"GDPR"
means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC;

"Information"
means this Information on the processing of personal data;

"Contact details of the Company"
means the following contact details that the Company has set up for contact with Customers:

(a) email: gdpr@axelor.group;

(b) phone: +420 777 886 107;

(c) data box: 3r2aefd;

(d) mailing address: the same as the address that is entered in the commercial register at any relevant time;

"Company"
means AXELOR SE, identification number 21986304, with registered office at Nové sady 988/2, Staré Brno, 602 00 Brno, a company registered in the Commercial Register under file number H 2692 with the Municipal Court in Prague;

"Data Subject"
means the person accessing the Website;

"Website"
means www.axelor.group and all publicly accessible components of this website;

"The Law"
means Act No. 110/2019 Coll., on the Processing of Personal Data, as amended;

2 FOR WHOM THIS DOCUMENT IS INTENDED

Within this document, the Company provides information on the processing and management of personal data for Data Subjects.

3 COMPANY STATUS

The Company is in the position of a data controller where it determines, alone or jointly with others, the purposes and means of processing personal data. If the Company is the controller, it is responsible for the proper processing of personal data and for compliance with the rights of Data Subjects or the legal standards applicable to the processing of personal data.

If the Company processes personal data without being the data controller, it is in the position of a processor. In such a case, it follows the instructions of the controller regarding the processing and it is the controller who is responsible for such handling of personal data.

4 CONTACT DETAILS

The Company can be contacted for matters relating to the processing of personal data at the Contact Details.

5 CATEGORIES OF PERSONAL DATA PROCESSED

The following list of personal data lists those personal data of potential Data Subjects that may be subject to processing by the Company and other persons mentioned in this document as a result of accessing the Website, specifically:

(A) Personal data processed through cookies. The Website uses cookies, which are small text files containing code that the Website places on the hard drive of the Data Subject's computer to ensure the functionality and effectiveness of the Website. In particular, cookies enable the Website to remember the Data Subject's preferences and settings during his/her time on the Website and/or until his/her next visit. Cookies are also used to enable statistical monitoring of the use of the Website, in particular with regard to data such as the frequency with which the relevant page of the Website is viewed, the time spent on the Website in a single visit or the detection of the moments at which the User leaves the Website.

(B) Data actively communicated by the Data Subject to the Company when using the Website - in particular when filling in any contact forms or in connection with such use. For example, the content of email communications or telephone calls may be processed in this way; in the case of prior consent, the telephone call with the Data Subject may be recorded. Data relating to contracts, agreements or other relationships between the Company and the Data Subject may also be subject to processing.

6 PURPOSE OF PROCESSING PERSONAL DATA

Executing the contractual relationship and fulfilling legal obligations

The Company uses the personal data of Data Subjects primarily to ensure that it can fulfil its contractual obligations to the relevant Data Subjects and the legal obligations arising from those obligations. For example, without the ability to process Data Subjects' personal data, it would not be possible to respond to messages left with the Company by Data Subjects.

Archiving

In accordance with the legal regulations, the Company processes the processed data of Data Subjects for a certain period of time after the first processing, for example, with regard to the obligations imposed on the Company in connection with the administration of taxes and other mandatory payments. The specific processing period is set out in Article 8.

Protection of legitimate interests

In order to protect its own legitimate interest, the Company processes the processed data of Data Subjects for a certain period of time after the first processing, for example to enable an effective procedural defence against any alleged claims of Data Subjects or to prove a certain factual situation. The specific processing period is set out in Article 8.

7 SOURCES OF PERSONAL DATA

The Company obtains the Personal Data of Data Subjects based on the submission of the Personal Data by the Data Subjects. In addition, the Company obtains personal data through the use of cookies in accordance with the above.

8 PROCESSING PERIOD

Different categories of personal data are processed by the Company for different periods of time depending on the purpose of their processing. Unless the duration of processing is determined by the consent given by the Data Subject, its duration is always governed by law, either directly or by inference.

The length of the processing period follows directly from the law where the law specifies how long documents or other documentation should be archived, typically in the case of legal regulation of bookkeeping.

The company considers the length of the processing period to be derived from the law if it relies on its legitimate interest to retain the personal data. In particular, the Company processes personal data in this way which may serve, for example, its procedural defence in the future when pursuing claims from Data Subjects or, conversely, when seeking performance from Data Subjects.

Specifically, the Company processes personal data in order to:

(a) the performance of the contractual relationship for a period of (i) 3 years from the date of termination of the relevant relationship or (ii) until the expiration of the time-barring period, in particular where it is contractually regulated for a period longer than the statutory period;

(b) to fulfill legal obligations and for archiving, for the period specified in the relevant legislation, in particular tax and accounting regulations;

(c) the fulfillment of the essence of cookies, for as long as they are stored on the Data Subject's computer and for as long as specified as the maximum permissible in the relevant legislation after the last interaction of the Website with cookies.

9 DATA PROTECTION OFFICER

The company has not appointed a data protection officer.

10 OTHER PROCESSORS OF PERSONAL DATA

Some of the personal data processed by the Company may, to the minimum extent necessary, be transferred to third parties for further processing, in particular to legal and natural persons, state authorities and public institutions, if this is necessary for compliance with legal obligations (including the obligation to keep proper accounting records of the Company) or the performance of contracts or the protection of the Company's rights and legitimate interests (e.g. relating to contractual rights, rights to compensation, etc.). These other persons may include, for example, carriers, software providers, accounting and tax firms, law firms, recruitment agencies, consultancies, auditors, etc.

The Company is entitled to transfer certain data to other processors on the basis of the Data Subject's partial explicit consent.

The Company is responsible for the way in which other processors of personal data handle this data.

11 OBLIGATIONS OF THE DATA SUBJECT

The Data Subject is obliged to provide personal data truthfully, accurately and completely. The Data Subject shall notify the Company without delay of any changes to the personal data, if the change is still relevant to the relationship with the Company.

12 INFORMATION ON THE RIGHTS OF THE DATA SUBJECT

Right to Access

The data subject has the right to request confirmation as to whether the Company processes his/her personal data and, if so, to obtain a copy of such data and information pursuant to Article 15 of the GDPR. If there is a large amount of such personal data, the Company may ask the Data Subject to specify the range of personal data for which he/she is requesting a copy.

Right to Repair

In accordance with the principle of accuracy expressed in the GDPR, it is the Company's duty and interest to keep the personal data it manages up to date. Therefore, data subjects have the right to request the correction of personal data and the obligation to notify the Company of changes to personal data.

Right to Erasure

Under the terms of Article 17 of the GDPR, the Data Subject may request the erasure of such personal data for the processing of which the Company has no legitimate interest or other lawful reason or ground under the GDPR. In particular, the Company shall not delete the personal data of the Data Subject if they are necessary for the establishment, exercise or defence of its legal claims. In other cases, the Data Subject may withdraw his/her consent to the processing of personal data and request their deletion.

Right to Limitation of Processing

Under the terms of Article 18 GDPR, the Data Subject may request that the Company restrict the processing of the Data Subject's personal data. This right may be exercised by a Data Subject who objects to the inaccuracy of the processed data or if the processing is unlawful, but the Data Subject does not request the erasure of personal data for the purpose of exercising his/her rights. The Company is entitled to continue processing if there are grounds for proving, asserting and/or defending its legal claims or for compliance with its legal obligations.

Right to Transfer

Where the processing is (i) based on the consent of the Data Subject or carried out for the purpose of performance of a contract and (ii) carried out by automated means, the Data Subject has the right to the release of personal data in a commonly used machine-readable format. Upon the Data Subject's request and subject to reasonably practicable requirements, the Company shall transfer the data directly to another controller.

Right to Object to Processing

When processing personal data for (i) the performance of a task carried out in the public interest, (ii) in the exercise of official authority vested in the Company or (iii) on the basis of a legitimate interest of the Company or a third party, the Data Subject has the right to object to such processing. Upon objection, the Company shall cease processing the Personal Data until the Company demonstrates legitimate grounds for processing on the part of the Company that proportionately override the interests, rights and freedoms of the Data Subject, failing which the Company shall either (i) delete the Personal Data or (ii) restrict the processing so that it is no longer processed for that purpose.

Right to Lodge a Complaint

The Data Subject shall have the right to, upon suspicion of breach of the Company’s processor obligations, request that the Company, as the controller of the personal data, remedy the unlawful situation, or to lodge a complaint with one of the competent supervisory authorities, in particular in the Member State of residence, place of work or place of alleged infringement. For the territory of the Czech Republic, the supervisory authority is the Office for Personal Data Protection, located at: Pplk. Sochor 27, Holešovice, 170 00 Prague 7, Czech Republic, website: www.uoou.cz, telephone: +420 234 665 111.

Right to Withdraw Consent

If the processing of personal data is based on consent, the Data Subject may withdraw consent at any time. Withdrawal of consent does not affect the processing already carried out. If the Company is aware of another legal reason for processing the relevant personal data, in particular a legitimate interest, the Company will be entitled to process the personal data of the Data Subject even after the withdrawal of consent.