PRIVACY POLICY

UNDERLYING COMMITMENTS OMNIA NAVAL DATA PRIVACY POLICY COLLECTING AND PROCESSING DATA FAIRLY AND LAWFULLY BEING OPEN ABOUT THE PERSONAL DATA WE COLLECT AND USE

We inform individuals about the use of their Personal Data When collecting Personal Data, OMNIA NAVAL informs clearly, honestly and transparently about the nature of the Personal Data it collects and what it intends to do with it. The use of Personal Data by OMNIA NAVAL for a different purpose than initially communicated is not authorized, unless adequate information is provided to the concerned individuals, and where applicable, consent for the intended use is given to OMNIA NAVAL. In general, OMNIA NAVAL is authorized to use Personal Data for secondary purposes when implementing internal controls and audits and complying with its statutory and regulatory obligations.

USING PERSONAL DATA FOR LAWFUL AND SPECIFIC PURPOSES ONLY

We collect and process Personal Data only if we have a lawful reason to do so OMNIA NAVAL collects and processes Personal Data only to the extent that either (i) a valid and informed consent was given or (ii) if it is required by OMNIA NAVAL legitimate business interests, such as entering into or performing contracts, processing and receiving payments, carrying out contractual obligations and complying with statutory or regulatory commitments. We allow consent given to be subsequently withdrawn Any consent given by individuals to the collection and use of their Personal Data must be given freely and in response to a clear information by OMNIA NAVAL about the intended use of the data. Such consent can be withdrawn anytime by the individual without undue complications. The date, content and validity of such consent must always be documented. We adhere to instructions given by the Data Controllers When processing Personal Data on behalf of a client or another third party (a Data Controller), OMNIA NAVAL will comply with the guidelines and instructions of the Data Controller in addition with this policy.

ENSURING DATA QUALITY

We collect and keep Personal Data which is adequate, relevant, not excessive and up to date OMNIA NAVAL collects and stores the minimum amount of Personal Data required for the intended initial purpose for which the data is used and ensures that, at all times, Personal Data in its possession remains relevant and adequate for its intended purpose. OMNIA NAVAL will keep all data stored up to date and accurate and will ensure it is corrected when required. We keep Personal Data only for as long as it is really necessary Personal Data is kept by OMNIA NAVAL only for the period of time required by its intended purpose. Specific retention policies will define the time after which such data will need to be either deleted, destroyed or de-identified.

RESPECTING INDIVIDUALS’ RIGHTS AND CHOICES RESPECTING INDIVIDUAL’S RIGHTS

We respond to any requests or complaints made by individuals in connection with their Personal Data OMNIA NAVAL recognizes the rights of individuals to: (i) Request access to the Personal Data collected on them by OMNIA NAVAL and the reason for OMNIA NAVAL having such data (ii) Obtain a copy of the Personal Data held on them (iii) Request the rectification or deletion of inaccurate or incomplete Personal Data (iv) Withdraw consent given to OMNIA NAVAL for the collection of their Personal Data at any time, including the right to unsubscribe or to opt out of marketing communications and commercial publications of OMNIA NAVAL OMNIA NAVAL will respond to requests made by individuals exercising their rights within a reasonable period of time after the individual’s request or within any specific period that may be required by applicable local laws. OMNIA NAVAL will handle and investigate complaints made by individuals about any breach of these rules or data privacy laws and will respond to such complaints in a timely manner.

RESPECTING INDIVIDUAL’S CHOICES

We respect customers’ rights to object to the use of their Personal Data or to opt out of receiving direct marketing communications When using Personal Data for marketing purposes, OMNIA NAVAL will inform individuals in a clear and plain language about the use of their data for marketing purposes. OMNIA NAVAL respects the right of its existing and prospective customers to: (i) only receive marketing communications from OMNIA NAVAL if an explicit and specific prior consent has been provided, when required by applicable laws, or if OMNIA NAVAL can demonstrate that it is authorized to send such communications for its legitimate business purposes (ii) no longer receive any marketing communications if a specific preference setting, an opt-out or an objection to use such data for marketing purposes has been received by OMNIA NAVAL

SAFEGUARDING THE USE OF SENSITIVE PERSONAL DATA

We use sensitive Personal Data only if it is absolutely necessary OMNIA NAVAL recognizes that some categories of Personal Data are particularly sensitive and require a higher level of protection. Sensitive Personal Data includes information regarding a person’s health, biometric and genetic data, religion and political opinions, racial or ethnic origin, criminal records and any other information protected specifically by the relevant applicable privacy laws. OMNIA NAVAL collects and processes such sensitive Personal Data only when this is absolutely necessary under one of the following circumstances: (i) Explicit consent was given by the individual (ii) The use is necessary for OMNIA NAVAL to comply with employment laws or other statutory obligations or to protect the health of the specific individual (such as in a medical emergency) OMNIA NAVAL implements adequate procedures and safeguards to restrict access to sensitive data only by appropriate persons and prevent its unauthorized access, use and dissemination.

MANAGING DATA RESPONSIBLY TAKING APPROPRIATE SECURITY MEASURES

We adhere to appropriate technical and organizational security measures to protect Personal Data OMNIA NAVAL implements adequate security measures to ensure the confidentiality, integrity and availability of Personal Data and to prevent the risk of unauthorized or unlawful access, alteration, destruction or disclosure of such data. The measures for protection are based on impact assessments taking into account the risk to the individual related to the specific Personal Data stored by OMNIA NAVAL. These measures include security and organizational measures adapted to the type of processing and the nature of the data to be protected. OMNIA NAVAL will inform individuals promptly of any privacy breach that has compromised their Personal Data and will report such incident to the relevant authorities as required by applicable laws. We ensure that our suppliers or partners also adopt appropriate and equivalent security measures OMNIA NAVAL requires from its suppliers or subcontractors that they fully comply with OMNIA NAVAL Data Privacy Policies, with any applicable data protection and privacy legislation and maintain adequate technical and organizational security arrangements to protect Personal Data. We ensure that our employees maintain the confidentiality of personal data processing OMNIA NAVAL limits access to Personal Data to those of its employees or suppliers who need to perform specific tasks in relation with such Data. Adequate awareness, training, and confidentiality undertakings are in place to ensure that Personal Data is not shared or disclosed to unauthorized persons, including any other OMNIA NAVAL employees who do not need to access such Personal Data.

ENSURING ADEQUATE PROTECTION FOR INTERNATIONAL TRANSFERS

When Personal Data is transferred, we ensure that we have taken steps to protect the Personal Data before transfer OMNIA NAVAL transfers Personal Data across national boundaries within the OMNIA NAVAL Group or outside the OMNIA NAVAL Group only when (i) this is justified for business purposes and (ii) safeguards exist to ensure that Personal Data will continue to be protected at a minimum with the same level of protection required in the jurisdiction of origin. MINIMISING RISK IMPACTS TO INDIVIDUALS If the processing is likely to result in a high risk to individuals, we conduct a Data Protection Impact Assessment OMNIA NAVAL conducts Personal Data Impact Assessments to identify risks that the processing of Personal Data by OMNIA NAVAL may cause to the privacy rights of individuals in order to eliminate or reduce such risks. Such prior Personal Data Impact Assessments will be part of any development of new services or business opportunities and acquisitions by OMNIA NAVAL