Privacy Notice

On the personal data processing activities carried out by VIT in relation to its trading counterparties_[1]

Vertis International Trading SE (hereinafter referred to as “VIT” or “data controller”) in accordance with Article 13 and 14 of the Regulation 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 (“General Data Protection Regulation”, “GDPR” or the “Regulation”), hereby provides information relating to the personal data processing carried out in the context of its relationship with its trading counterparties.

Identity and contact details of the data controller

Name of the controller: Vertis International Trading SE

Seat of the controller: Csörsz utca 45, 1124 Budapest, Hungary

Email: privacy@vertisit.com

Purpose, legal basis and retention period of the processing, in relation to each category of personal data processed

A) In the context of our counterparty onboarding and “Know Your Customer” processes, regarding legal entity counterparty’s representatives, executive officers or authorised proxies or natural person counterparties (if any) as data subjects

Purpose of data processing	Personal data processed	Legal basis	Retention period
Carrying out customer due diligence measures in accordance with our “Know Your Customer” (KYC) regulation	First name and surname Data included in the commercial/company register Data contained in the document serving as proof of authority to represent the trading counterparty Title/position, corporate email address Personal data (if any) contained in the evidence of professional / eligible status Personal data made available by Worldcheck or on social media platforms (regarding signatories of high risk ETS trading counterparties or if needed based on risk indicators ) CV of signatories and management (of medium and high risk F-Gas clients)	VIT’S legitimate interest in conducting careful customer due diligence procedures (which entails verifying the identity and background of the counterparties for risk management purposes)	Eight years after the end of the business relationship or after the date of last transaction
Monitoring sanctions lists for the purposes of our KYC process and compliance checks	The fact of appearing / not appearing on FATF, EU or UN sanctions lists (only in case of medium or high risk trading counterparty)	VIT’S legitimate interest in conducting careful customer due diligence procedures and the avoidance of possible sanctions	Eight years after the end of the business relationship or after the date of last transaction
Monitoring US sanctions lists, in case it is required by relevant trade or other prohibitions, if these are applicable to VIT	The fact of appearing / not appearing on US sanctions lists	VIT’S legitimate interest in conducting careful customer due diligence procedures, as well as the smooth processing of payments and the avoidance of possible sanctions	Eight years after the end of the business relationship or after the date of last transaction

_{[1] This privacy notice has been prepared for information on data processing with regard to those persons’ personal data who act as trading counterparties (if natural persons) or as representatives, executive officers, authorised proxies, beneficial owners or similar persons acting on behalf of a trading counterparty. However, in certain situations (especially in the period preceding or aiming that a person or entity become a trading counterparty to VIT) it also covers data processing relating to such persons who act on behalf of entities which are not (yet) trading counterparties but prospective counterparties or other business partners of VIT.}

B) In the context of our onboarding and “Know Your Customer” processes, regarding the Trading counterparty’s beneficial owners/controllers as data subjects

Purpose of data processing	Personal data processed	Legal basis	Retention period
Carrying out customer due diligence measures in accordance with our “Know Your Customer” (KYC) regulation	First name and surname Nationality Country of residence Nature/extent of the ownership/control Personal data made available by Worldcheck or on social media platforms (regarding signatories of high risk ETS trading counterparties or if needed based on risk indicators)	VIT’S legitimate interest in conducting careful customer due diligence procedures (which entails verifying the identity and background of the trading counterparties for risk management purposes)	Eight years after the end of the business relationship or after the date of last transaction
Monitoring sanctions lists for the purposes of our KYC process	The fact of appearing / not appearing on FATF, EU or UN sanctions lists (if categorisation based on our KYC matrix is medium or high risk)	VIT’S legitimate interest in conducting careful customer due diligence procedures and the avoidance of possible sanctions	Eight years after the end of the business relationship or after the date of last transaction
Monitoring US sanctions lists, in case it is required by relevant trade or other prohibitions, if these are applicable to VIT	The fact of appearing / not appearing on US sanctions lists	VIT’S legitimate interest in conducting careful customer due diligence procedures, as well as the smooth processing of payments and the avoidance of possible sanctions	Eight years after the end of the business relationship or after the date of last transaction

Please note that personal data collected in the context under point A) to B) above, provided such Trading counterparty consents which may be required under applicable regulation are available, may be used and processed by VIT for any due diligence process relating to other Counterparties if the same individual holds a position of representative, executive officer, authorised proxy or beneficial owner at that other entity. Such use for additional data processing purposes of the collected personal data shall be based on our legitimate interest in keeping record of the most accurate and all available information necessary for the due diligence process with the least administrative burden possible to our Trading counterparties.

C) In the context of certain of our business activities in the event that the Counterparty is a private entrepreneur (not a legal entity) (eg. a private entrepreneur operator with compliance obligations or a new entrant F-gas quota holder) – please note the data processing activities listed below are additional to those listed in points A) to G) as applicable to natural person Trading counterparties.

Purpose of data processing

Personal data processed

Legal basis

Retention period

Carrying out customer due diligence measures in accordance with our “Know Your Customer” (KYC) regulation

Personal identification data, private entrepreneur registration number, VAT number, registry account number

VIT’S legitimate interest in conducting careful customer due diligence procedures (which entails verifying the identity and background of the trading counterparties for risk management purposes)

Eight years after the end of the business relationship or after the date of last transaction

Preparing and performing contract;
Enforcement of legal claims (if any)

Full name, identification data, private entrepreneur registration number, VAT number, registry account number, bank account details, trading data and all details of the contractual relationship which qualify personal data

Performance of the contract to which the data subject is party and taking steps at the request of the data subject prior to entering into a contract;
In the event of enforcing legal claims, our legitimate interest in the availability of the necessary evidence

Eight years after the end of the business relationship or after the date of last transaction
In case of enforcement of legal claims, until the relating legal procedures are closed

D) In the context of our communication and business cooperation with our trading counterparties, regarding the representatives and contact persons acting on behalf of our trading counterparties, or natural person counterparties (if any) as data subjects

Purpose of data processing	Personal data processed	Legal basis	Retention period
Maintaining business communication with trading counterparties, including recording communications Secondary purposes in relation to the recorded content: Providing internal courses to employees for quality assurance Verification of the content of transactions, availability of evidences in case of disputes Internal monitoring of sales staff’s compliance with relevant legal obligations and internal regulations, prevention of fraud, corrupt or other illicit practices or behaviour	Name, contact details (business email and phone number), data contained in the communication (outgoing and incoming telephone conversations and electronic messages letters, faxes, instant chat and e-mail messages) Personal data that may appear in the content of customer-related notes, minutes of personal meetings, data necessary for possible legal claims If the communication is recorded, the recording	Legitimate interest of VIT and its Counterparty in carrying out their business operations, maintaining business relations and in the fulfilment of concluded contracts, as well as the availability of evidence in the event of enforcement of legal claims related to the business relationship In relation to the secondary data processing purposes, the legal basis is VIT’S legitimate interest in improving quality service enforcing legal claims, clarifying transaction details and resolving disputes ensuring compliance by relevant staff and preventing fraudulent, corrupt or other illicit behaviour	Eight years from the end of business relationship (or, in case of enforcement of legal claims, until the respective legal procedure is closed) In case the data referred to herein is contained in invoicing or taxation document, until the end of the relevant document retention period prescribed by law (see below at “Complying with document retention obligations”) In case there is a legal procedure in which the recorded call or other recorded information is used, until the closing of such procedure (by a binding and final decision, where applicable)
Providing the service “MyVertis”	Email address, access code, passwords, user profile data (name, company, position, telephone number, language); user data, Terms acceptance, and data for any possible legal claim enforcement	The legitimate interest of VIT and its trading counterparty in the provision and use of the MyVertis service, to the trading counterparty In case of a natural person Trading counterparty, Performance of the contract to which the data subject is party and taking steps at the request of the data subject prior to entering into a contract In the event of enforcing legal claims, our legitimate interest in the availability of the necessary evidence	Five years after registration To data listed here also appearing in communication or files with longer retention period, the longer retention period indicated at the relevant row may apply
Forwarding Trading counterparty’s information to the brokered/introduced partner, within the framework of the provision of introducing/brokerage services, or fulfilment of contractual obligations arising from engagements aiming the creation of business cooperation between counterparties	Contact details of representatives, executives or other personnel of the trading counterparty (or of the trading counterparty him/herself, in case of natural person)	Legitimate interest of VIT and its trading counterparty in providing the relevant service or fulfilling a contractual obligation In case of a natural person trading counterparty, performance of the contract to which the data subject is party and taking steps at the request of the data subject prior to entering into a contract	The retention periods indicated at other data processing purposes (with special regard to recording communication) apply

E) In the context of transferring trading counterparty information to Financing Partners

Please note that the below data processing activities take place only if Your company is affected by services we engage from banks, insurers or other financing partners as well as their brokers or agents (“Financing Partners”), in relation to factoring and similar services, also involving financing and/or insurance related to the collection of outstanding debt/receivables of our business partners. For that aim VIT requests a data sharing consent from its trading counterparty (either within an agreement or in a separate document), so transfer of the personal data is also dependent on such consent.

Purpose of data processing	Personal data processed	Legal basis	Retention period
Enabling the Financing Partner to contact the trading counterparty in relation to the enforcement of the rights (claims, receivables) assigned to it by VIT, in particular to communicate with the trading counterparty in payment-related matters or other matters related to its services	Name and position; contact details (business email address, business phone number), language preferences, if any	VIT’S and the Financing Partner’s legitimate interest in carrying out their business operations under the services provided by the Financing Partner to VIT, in relation to the business relationship between the trading counterparty and VIT	One-time data forwarding, no retention period applies

F) In the context of our own or group-level marketing activities

Purpose of data processing	Personal data processed	Legal basis	Retention period
Enabling Vertis Environmental Finance Ltd to send VERTIS newsletters to You (which may include invitation to VERTIS marketing events)	Full name, business e-mail address, company, position	Your Consent	Until revocation of your consent
Sending You Christmas seasons or other similar greetings, gift	Full name, business e-mail address, company, position In case of sending a gift, company mailing address and business mobile number (so the courier can contact You for delivery)	Our legitimate interest in constructing and maintaining good business relationship	Until the end of our business relationship or the end of your role/position at our trading counterparty which gave us grounds for maintaining business contact
Introducing You to other Vertis/STX Group members for services these may offer to you	Full name, business e-mail address, business phone number, company, position, in situations onboarding at VIT has already been commenced or performed earlier, such onboarding data which is necessary for the onboarding at the receiving group entity	Your Consent or, if a consent was given to that by the entity you act on behalf of, our and the Trading counterparty’s legitimate interest in further business cooperation between the Trading counterparty and Vertis/STX Group	One-time data forwarding, no retention period applies

G) In the context of our internal administrative processes, regarding all data subjects mentioned above

Purpose of data processing	Personal data processed	Legal basis	Retention period
Preparing back-up copies of documents kept in our IT systems, implementing measures of data loss prevention	All data stored in our IT system	The legitimate interest of VIT in ensuring the uninterrupted operation of its IT processes and taking the necessary steps to ensure data security	Five years
Complying with document retention obligations	Data contained in documents relating to invoicing/accounting or taxes	Compliance with the legal obligation to which VIT is subject, as set out in the Hungarian Accounting Act and Act on Taxation Procedures	Accounting documents: eight years, taxation documents: the end of the calendar year affected by the tax declaration obligation + five years

Sources of personal data

The sources of the personal data are normally you as the data subject or your company, in the course of our business communication. Should the counterparty be introduced by an engaged introducer or broker, some data as for example contact details of representatives and other persons acting on behalf of the counterparty, may be provided by such introducer or broker.

In the context of our KYC customer due diligence processes, or other onboarding processes, we may also rely on public registries, other publicly accessible data sources and sanctions lists in order to obtain your data.

In the context of business communications, minutes or messages, the source of data is the sender of the communication or the person who took the minutes.

Other information on our data processing

Provision of your personal data is a statutory requirement in all those events where we refer to a legal obligation VIT is subject to. Provision of your data is not a requirement necessary to enter into a contract directly with you (except for natural persons acting as trading counterparties, the data required for such contract), but it may be necessary to enter into a contract with the company you represent or on behalf of which you act towards us. Consequently, you are generally not obliged to provide the personal data, but it might be an obligation for your company or for VIT to obtain and process them. Possible consequences of failure to provide your data may be that VIT cannot enter into or maintain business relationship with its counterparty.

Where the legal basis for the data processing is Your consent, You can withdraw the consent at any time; however, the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Recipients of the personal data

In the context of the data processing activities referred to in this privacy notice, personal data shall be shared with the following addressees, in relation to the below detailed services VIT has engaged in order to be able to operate its systems and pursue its business activities. Most of such addressees, if they provide services to VIT, act as data processors providing the guarantees to implement appropriate technical and organisational measures in line with the rules of GDPR, while some may act as joint data controllers. In order to ensure protection of your data, international service providers such as Microsoft, Zoom and others mentioned in the below list, when acting as data processors, involve numerous sub-processors, which are published and updated from time to time on their respective webpages.

Data category	Addressee	Activity or role which serves as grounds for the data sharing
All data processed by VIT for the purposes of electronic communication or storage of files, administrative and other operations	Vertis Environmental Finance Ltd. and its sub-processors: Microsoft Ireland Operations Limited for e-mail correspondence, Skype for business and Teams application London Stock Exchange Group (UK) for the “Eikon” Instant messaging service International Exchange Ltd. (USA) for “ICE chat” Instant messaging service WhatsApp Ireland Limited (Ireland) for “WhatsApp” Instant messaging service Keepit A/S (Denmark) for Storage of back-ups MesterCom Kft. (Hungary) for IT support service	Provision of IT, accounting, legal and other support services to VIT, including the “myVertis” service
Business contact data in case of brokerage services or other services aiming creating business cooperation between trading counterparties	The other trading counterparty affected by the service / business cooperation	Brokerage services or other services aiming creating business cooperation between trading counterparties
Data used for reporting obligations, procedures or audits by authorities and by the statutory auditor	Competent authorities (or regulatory authorities auditing main service providers’ operations); KPMG Hungária Kft. (Hungary; appointed statutory auditor)	Compliance with legal (eg. reporting) obligations, supervisory audits or administrative procedures; performance of annual statutory audit
Contact data as referred to in point E) above	Financing Partner (as defined in point E) above)	See description of the data transfer in point E) above
Data necessary for the delivery of a gift	The courier service provider involved in delivery	Sending Christmas or other gift to counterparties
Data contained in documents necessary for enforcement of legal claims	Legal advisors, courts	Enforcement of legal claims

Data transfer to third countries

Data transfer to third countries is carried out by VIT in the following events, in relation to the involvement of the following service providers. The chart below also provides you with information regarding the safeguards applied in relation to such data transfers.

Service provider / other addressee	Third country to which data are transferred	Safeguards for ensuring proper protection for the data	When does it happen?
London Stock Exchange Group	United Kingdom	Adequacy decision of the EU Commission	In case of communication through Eikon instant messaging service
International Exchange Ltd.	USA	Standard Contractual Clauses	In case of communication through ICE chat service
Zoom Video Communications, Inc.	USA	Standard Contractual Clauses	In case of communication through the Zoom application

If, for the purposes of our data processing relating to the provision of brokerage/introducing services, or other engagements we have for creating business cooperation between our trading counterparties, it is necessary to transfer personal data to third countries or international organisations, we will ensure that proper safeguards are implemented to protect your personal data, either because there is an adequacy decision regarding the receiving country, or by using other safeguards such as standard data protection clauses adopted by the European Commission, or specific contractual clauses concluded with the receiving party.

Automated decision making, including profiling

Automated decision making, including profiling, does not occur in the context of the data processing referred to in this Privacy Notice.

Your rights in relation to our data processing activity

As a data subject, you can exercise

the right to access;
the right to rectification;
the right to erasure (right to be forgotten);
the right to restrict the processing
the right to object to the processing of your personal data,

subject to the conditions as set out by the GDPR.

In addition, where the legal basis of the data processing is the performance of a contract You are a party to or Your consent, You shall also have the right to data portability.

Right to access

You as data subject shall have the right at any time to request information whether your personal data are processed, and if so, in what manner such data are processed by the data controller, including the purposes of the processing, recipients to whom the personal data have been or will be disclosed, the source of information from where the data controller obtained such data, the retention period of such data, any right that they may have concerning the processing, and where personal data are transferred to a third country or any international organisation, you as data subject shall have the right to be informed of the appropriate safeguards relating to the transfer. When exercising the right of access, the data subject shall also be entitled to request copies of such data. In the event the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in an electronic form. If the right of access exercised by the data subject would affect adversely the rights and freedoms, in particular the business secrets or intellectual properties of others, the data controller shall have the right to refuse the request of the data subject to the extent necessary and proportionate. For any further copies of the above information requested by the data subject, the data controller may charge a reasonable fee that is proportionate to the related administrative costs.

Right to rectification

The data controller shall rectify or supplement the personal data of the data subject based on any related request from the data subject. Where there is any doubt concerning any rectified data, the data controller may call upon the data subject to adequately verify, preferably by an official document, the rectified data for the data controller. If the data controller has disclosed the personal data affected by such right to any other persons (i.e. to another recipient e.g. the data processor), the data controller shall inform such persons of the rectification of such data without delay, provided that it is not impossible or does not require a disproportionate effort from the data controller. At the request of the data subject, the data controller shall inform the data subject of the identity of these recipients.

Right to erasure (“right to be forgotten”)

Where You as data subject request the erasure of any or all of your personal data, the data controller shall have the obligation to erase those without undue delay, if:

the data controller does not need the affected personal data in relation for the purposes for which they were collected or otherwise processed;
processing was based on your consent, however, you have withdrawn your consent, and there is no other legal ground for the processing;
processing was based on the legitimate interest of the data controller or a third party, however, You have objected to the processing, and there are no overriding legitimate grounds for the processing, except for objection to data processing for direct marketing purposes;
the personal data have been unlawfully processed by the data controller, or
the personal data have to be erased for compliance with a legal obligation.

If the data controller has disclosed the personal data affected by such right to any other persons (i.e. to another recipient e.g. the data processor), the data controller shall inform such persons of the rectification of such data without delay, provided that it is not impossible or does not require a disproportionate effort from the data controller. At the request of the data subject, the data controller shall inform the data subject of the identity of these recipients. The data controller shall not always be required to erase the personal data, in particular where e.g. the data processing is necessary for the establishment, exercise or defence of legal claims.

Right to restriction of processing

You as data subject may request restriction of processing in relation to your personal data where one of the following applies:

the accuracy of the personal data is contested by the data subject, in this case restriction of processing shall be applied for a period enabling the data controller to verify the accuracy of the personal data;
the processing is unlawful, but the data subject opposes the erasure of the data, and requests the restriction of their use instead;
the data controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise and defence of legal claims; or
the data subject has objected to the processing, in this case restriction of processing shall be applied until it is verified whether the legitimate grounds of the data controller override those of the data subject.

Restriction of processing means that such personal data shall not be processed by the data controller or shall, with the exception of storage, only be processed with the data subject’s consent, or in the absence of such consent the data controller may also process these data for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a member state of it. The data subject shall be informed by the data controller before the restriction of processing is lifted. If the data controller has disclosed the personal data affected by such right to any other persons (i.e. to another recipient e.g. the data processor), the data controller shall inform such persons of the rectification of such data without delay, provided that it is not impossible or does not require a disproportionate effort from the data controller. At the request of the data subject, the data controller shall inform the data subject of the identity of these recipients.

Right to object

Where processing of data concerning You as data subject is based on the legitimate interest of the data controller or a third party, You as data subject shall have the right to object to processing of data. The data controller shall not be obliged to accept such objection, unless the data controller demonstrates

compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or
that the data processing is related to the submission, enforcement or protection of the data controller’s legal claims.

The right to data portability

Right to data portability generally means that the data subject shall have the right to receive the personal data concerning him/her, which he/she provided to the data controller based on consent or on a contract, and are processed by the data controller by automated means (e.g. in a computer system), in a structured, commonly used and machine-readable format, and have the right to transmit those data to another controller, or the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

In addition to the above, as a data subject, you have the right to lodge a complaint with a supervisory authority, in particular in the member state of the EU of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR. For a list of the data protection supervisory authorities, see https://edpb.europa.eu/about-edpb/about-edpb/members_en. You may also enforce your rights in court pursuant to the provisions of the GDPR and the Hungarian Civil Code or other legislation applicable to you.

Additionally, according to Art. 25 of the Hungarian Act CXII of 2011 on the right to informational self-determination and freedom of information, the close relative of the deceased data subject or the person authorized by the deceased data subject might exercise data subject rights as determined by that Act within 5 years from the date of the death.

How we handle your requests or questions in relation to our data processing activities

We shall provide information on the action taken on your questions or requests submitted to us relating to the processing of your personal data or to the exercise of your rights as data subject, without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests we receive. We shall inform You of any such extension within one month of receipt of the request, together with the reasons for the delay. If You make the request by electronic means, we shall also provide you our answer by electronic means where possible, unless otherwise requested by You. Should it be the case that we do not take action on your request, we shall inform You on that without delay and at the latest within one month of receipt of the request, explaining you the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.