Data Protection

Vallis and Pontem Accountants respects all applicable Data Retention and Data Protection Provisions.

  1. Data Protection Legislation means the following to the extent applicable from time to time:

(a) up to and including 24 May 2018, the EC Data Protection Directive (Directive 95/46/EC)     and all legislation implementing that Directive;

(b) on and from 25 May 2018, the General     Data Protection Regulation (Regulation     2016/679); and

(c) any similar laws and regulations relating to the processing of personal data. Controller     and process (and its derivatives) shall     have the meanings given to them under relevant Data Protection Legislation.

2. Personal Data means all personal data (as that term is defined in relevant Data Protection

Legislation) provided to Vallis and Pontem Accountants pursuant to our engagement with the     Principal and the Client Entity    or generated by Vallis and Pontem Accountants in the     course of its engagement with the Principal and the Client Entity.

3. Vallis and Pontem Group means Vallis and Pontem Accountants S.A., its subsidiaries and     the other partnerships, corporations, undertakings and entities which are authorised to practise     using the name “Vallis and Pontem”.

4. Retention of matter files
Vallis and Pontem Accountants will destroy documents relating to a matter (both our paper     and, where practicable, electronic files) when considered that it is not needed to keep them.

5. Data protection

(a) Vallis and Pontem Accountants will comply with applicable Data Protection Legislation     when processing the Personal Data.

(b) The Principal, the Client Entity and the individuals of the company or any group the    company belongs to (the Data     Subjects) are informed that Vallis and Pontem Accountants act     as an     independent data controller when processing Personal Data in the course of its work     for the     Principal or for the Client Entity. Vallis and Pontem Accountants will for instance     process the Personal Data (a) to meet its legal and regulatory obligations, (b) in pursuing our     legal rights, and (c) for administrative, compliance, financial, risk management and client     relationship purposes.

(c) The Principal and the Client Entity agree that Vallis and Pontem Accountants may transfer Personal Data within the Vallis and Pontem Group and to third party service providers, including to jurisdictions outside the European Economic Area, in compliance with applicable     Data Protection Legislation.

6. The Principal and the Client Entity are responsible for ensuring that the Personal Data y    provided to Vallis and Pontem Accountants complies with applicable Data Protection Legislation and they will not do or omit to do anything that would cause Vallis and Pontem     Accountants to be in breach of the Data Protection Legislation. The Principal and the Client  Entity undertake to forward the content of the abovementioned privacy policy to all concerned Data Subjects within their organization. They shall indemnify and hold Vallis and Pontem     Accoutants harmless for any and against all direct and indirect damages and financial consequences arising from any breach of these warranties or your undertakings.