External Public Privacy Notice

This notice applies to all countries except South Africa.

View privacy notice for South Africa:

• English version

You can view this notice in the following languages:  Chinese (Simplified), Dutch, Greek, Estonian, Finnish, French, Italian, Polish, Portuguese (Brazil), Russian.

1. Introduction

This External Public Privacy Notice ("Notice") applies to the Accelleron Group of companies, which means Turbo Systems Switzerland Ltd, Switzerland and each entity in which Turbo Systems Switzerland Ltd, Switzerland, directly or indirectly, has a majority holding or owns or controls the majority of voting rights. The Accelleron company that is communicating with you or to which you are providing goods or services (referred to as "Accelleron" or "we"), is responsible for the processing of your personal data and controls how it is used, in accordance with this Notice.

At Accelleron, respecting your data privacy rights is a top priority. This notice explains why and how we collect personal data about you, how we process such data, and what rights you have regarding your personal data.

2. Who is responsible for the processing of your personal data?

Turbo Systems Switzerland Ltd and its subsidiary companies are responsible for your personal data. For applicable data protection law, the primary controller of your data will be the Accelleron subsidiary company, which is providing services or communicating to you. Other subsidiary companies of Accelleron may also receive and process your personal data, either in the capacity of controller or processor and this Notice applies equally to them.

3. The personal data we collect about you and how we get it

We collect and use personal data that concerns you in connection with the relationship with you. We may collect the following categories of personal data:

• The business contact information you share with us: name, title, job title, email address, business address, telephone number, mobile telephone number.
• Additional information you provide to us in the course of our business relations, such as: interests in Accelleron products, communication preferences, registration information provided at events, fairs, contract or order data, invoices, payments, business partner history, etc.
• Information your browser makes available when you visit an Accelleron website: IP address, the source of your site visit, time spent on the website or a particular page, links clicked, comments shared, browser type, date and time of visit, etc.
• To the extent necessary to fulfil our obligations, data obtained from publicly accessible sources or which are legitimately transmitted by other third parties (e.g. a credit agency): commercial register data, association register data, creditworthiness data.

In case you would like to be provided with information about a specific personal data processing activity, you can request that by submitting a request at www.accelleron-industries.com/privacy .

4. What we use your personal data for

We may use your personal data as described above for the following purposes:

• maintain and cultivate our relationship with you;
• invite you to our events;
• to organize meetings between you and our executives;
• send you communications in case you indicate your interest in receiving such information (such as press releases about financial results, services, products, initiatives and invitations to events or meetings etc.); and
• conduct and facilitate surveys.

We collect only the personal data from you that we need for the purposes described above. For statistical purposes, improvement of our services and testing of our IT systems we use as much as reasonably possible anonymized data. This means that these data can no longer (in)directly identify you or single you out as an individual.

5. The legal basis we rely on

We use your personal data for the purposes described in this notice based on one of the following legal bases, as applicable:

• We will ask your consent for the activities described in this privacy notice when required by applicable law, for example communications materials and events; or
• We will rely on our legitimate interests to process your personal data within the scope of the professional relationship with you or your company or your organization. Our legitimate interests to collect and use the personal data for this purpose are management and furtherance of our business or relationship with you.

You may obtain a copy of our assessment of why we may process your personal data for these interests by submitting a request at www.accelleron-industries.com/privacy.

6. Parties we share your personal data with (in and outside the EU and EEA or outside the country where the Accelleron company that controls your data is located)

We only share your personal data with other Accelleron affiliates, subsidiaries or third parties as necessary for the purposes described in the table below. Where we share your personal data with an affiliate or third party so that it is transferred to or becomes accessible from outside the European Union (“EU”) and the European Economic Area ("EEA") or outside the country where the Accelleron company that controls your data is located, we always put adequate safeguards in place to protect your personal data. Examples of these safeguards are an adequacy decision of the European Commission (read more here), Standard Contractual Clauses (read more here), Privacy Shield certification (read more here), and the Binding Corporate Rules that some of our services providers have adopted (read more here). We have taken additional measures for the transfer of data from within to outside the EU, EEA and outside the country where the Accelleron company that controls your data is located to protect your personal data. If you would like an overview of the safeguards which are in place, please submit a request at www.accelleron-industries.com/privacy.

7. How long we keep your personal data

Based on mandatory legislation, Accelleron must keep certain personal data for a minimum period of time. We only keep your personal data for as long as necessary for the purposes described in this privacy notice.

At the same time, applicable data protection laws require that we do not keep personal data in an identifiable form for any longer than is necessary for the purpose for which the personal data is being processed. Through the setting of IT applications and policies we ensure that our keeping of your personal data is deleted when we no longer need it.

For more information regarding specific retention periods that apply to your personal data, please submit a request at www.accelleron-industries.com/privacy.

8. Your data privacy rights

Depending on the jurisdiction in which you are located and in which your personal data is processed, you may have the following rights:

Please note that the rights described above are not absolute, and that your request cannot always be met entirely. For example, sometimes we cannot delete or restrict the processing of your personal data as we may have legal obligations or contractual obligations to keep certain such personal data.

You may request to enforce your data privacy rights at www.accelleron-industries.com/privacy.

Contact and further information

If you want to access your personal data, make use of any of your other rights mentioned above or if you have any questions or concerns about how Accelleron processes your personal data, please contact our Group Data Protection Officer at privacy@accelleron-industries.com, or submit your complaint at www.accelleron-industries.com/privacy.

Should you not be satisfied with our response or believe we are processing your personal data against the law, you may also have the right to file a complaint with the Data Privacy Authority in your country of residence or work, or seek a remedy through the courts where you believe an infringement of data privacy laws may have taken place.

Date of publication: September 30, 2019