This privacy policy describes the collection, storage, and use of your personal information that we, Peaberry-up, collect and use within the framework of our relationship with you as a supplier, vendor, consultant, candidate, provider, distributor, healthcare provider, or patient.

This policy may apply to you in various aspects or only some of them.

You have the right to be informed about our data processing practices and to control the personal information we hold about you.

Therefore, this document aims to provide you with transparent and detailed information on how and why we collect, store, and use your personal information, as well as how you can exercise your rights under data protection legislation.

This privacy policy was published on March 2025.

1) Who We Are
Peaberry-up S.R.L. is a company headquartered at Rue Willems 14, 1212, 1210 Brussels, Belgium, and registered with the Crossroads Bank for Enterprises under the number 0866.713.410 (“Peaberry-up” or “We”).
As the data controller, we respect your right to privacy and process only the personal information you provide us in accordance with applicable data protection laws and as described in this policy. (Applicable data protection laws include (i) the General Data Protection Regulation (Regulation 2016/679) (“GDPR”) and (ii) all other existing or new laws related to or impacting the processing of personal information and privacy).
If you have any questions about how we collect, store, and use your personal information or any other privacy-related inquiries, please email us at daniel@peaberry-up.com.

2) The Personal Data We Collect About You and the Purposes for Processing
Below is an overview of:
• The categories of personal data that we (or third-party data processors acting on our behalf) may collect, use, and store about you;
• The purposes for which this information is collected;
• The legal basis for processing.
Overview of the Categories of Personal Data We May Collect, Use, and Store:
• The information we may collect and process includes:
◦ Contact details such as name and address
◦ Email address
◦ Bank account details
◦ VAT number or company registration number
◦ Specialty
◦ Metadata (including sender and recipient details, IP addresses used, server information, date, time, read receipts, and acknowledgments related to communications between you and Peaberry-up)
◦ Company details and company registration number
◦ National registry number
◦ Authorization to send information/offers regarding products
◦ CV (including previous professional background or reference details)
◦ Value transfers (as part of the Sunshine Act)
◦ Website usage data

Data Collected in Specific Situations:
For candidates specifically, we may collect contact details (name, address, phone number), evaluation forms, CVs, references, social media information (e.g., LinkedIn), background checks (confirmation of qualifications), and interview notes.

We retain and use this information to make decisions regarding recruitment before entering into a potential employment contract.CCTV Surveillance. We may collect CCTV video recordings at our premises. Peaberry-up ensures that all individuals are informed via signage at the property entrance and that this is in compliance with all applicable regulations concerning CCTV recordings.

We retain and use this information for security purposes on our premises.
Cookies and Similar Technologies: We may collect personal information about you as described in our cookie policy, accessible at www.peaberry-up.com.
3) For What Purposes Do We Process and Use Your Data?
Peaberry-up collects and processes your personal data for the purposes described below. Processing is limited to the specific purposes of its activities, and Peaberry-up ensures that only necessary and relevant data for these purposes are processed.
Generally, Peaberry-up processes your data in legally permitted situations, specifically:
• To comply with Peaberry-up’s legal obligations;
• To take necessary pre-contractual measures and to execute contracts;
• To achieve and pursue Peaberry-up’s legitimate interest, ensuring a fair balance between its interests and your rights and freedoms;
• In specific cases, based on your consent—given following a specific and unambiguous request, preceded by clear and understandable information—which you can withdraw at any time in accordance with the law.
3.1 Compliance with the Law
Peaberry-up is bound by numerous laws and regulations that require your data to be processed as part of its various activities. These obligations may require Peaberry-up to cooperate with competent authorities and/or third parties and, where necessary, share some of your data with them.
These obligations fall, among others, within the following legal and regulatory areas:
• The Belgian Income Tax Code (preparation of the annual profit and loss statement 281.50) and, more generally, Peaberry-up’s obligation to contribute to the fight against fraud and tax evasion.
3.2 Contractual Relationship with Peaberry-up
In certain cases, Peaberry-up may need to obtain and process certain data before entering into contracts, particularly in order to:
• Respond to your inquiries or requests regarding products or services;
• Determine and ensure the conditions under which the contract will be concluded.
As part of the execution or management of existing contracts, Peaberry-up must implement various processes and data processing operations in different forms to meet its administrative and accounting obligations and manage its business relationships with you.

This may include processing personal data for:
• General administration, such as processing or executing any document, transaction, operation, project, or task underlying the business relationship (e.g., contracts, purchase orders, delivery, shipping or customs, project management, invoicing of tangible and intangible services, payments, etc.);
• Organizing your participation in an event; providing you with practical/logistical information about the event; enabling you to benefit from Peaberry-up’s rewards and advantages within the limits set by applicable law;
• Fulfilling obligations or enforcing Peaberry-up’s rights related to our contractual or business relationship with you or a third party;
• Organizing meetings or events;
• Negotiating contract terms;
• Participating in public or private tenders;
• Supporting and justifying Peaberry-up’s position, claims, arguments, defense, or conclusions in disputes and legal proceedings involving you or a third party;
• Analyzing the use of our website to continuously improve its content and measure performance;
• Optimizing and adapting the use of our website and communication with you.
In this context, your data may be shared internally within Peaberry-up or with close collaborators, including those who are not directly responsible for the contractual relationship with you or the execution of a particular contract.
Peaberry-up may process your data for other additional purposes related to the contractual relationship it has with you and the execution of the contract.
3.3 Peaberry-up’s Legitimate Interest
Peaberry-up also processes your data to fulfill its legitimate interests. To this end, Peaberry-up strives to balance the need to process your data with respecting your rights and freedoms, including the protection of your privacy.
Personal data is therefore processed for the following purposes:
• Technical commercial information: Analysis of potential competitors and business partners, prospecting, and evaluation of potential business partners;
• Public relations: Marketing and goodwill creation for the organization. Peaberry-up may (i) ask for your feedback to improve its services; (ii) send you invitations to participate in events; and (iii) send you targeted advertisements that may interest you;
• Market research: Studies on behaviors, preferences, and other intentions of individuals to determine business strategies;
• Security: Ensuring the safety of people and property;
• Statistical research: Conducting statistical surveys;
• Historical research: Using private or public archives to analyze past events or enable such analysis.
Peaberry-up’s Specific Legitimate Interest: Direct Marketing
Peaberry-up conducts market segmentation and profiling, particularly based on business activities, to offer you services tailored to your professional and personal situation.
Peaberry-up may process your personal data, among others, to:
• Send you professional information or advertisements that may interest you and send you satisfaction surveys about the services Peaberry-up provides, in accordance with applicable law;
• Ask for your feedback to improve its services; send you invitations to participate in events; and send you targeted information or advertisements that may interest you. To improve the quality of service provided to you, Peaberry-up may analyze metadata related to its exchanges with you;
• Analyze customer or prospect behavior and preferences based on purchases and other parameters and/or customer interactions, in order to design and prepare its marketing or communication campaigns.
Your Consent for Electronic Communications
Peaberry-up may process your electronic contact information, namely your mobile phone number and email address, to send you personalized information, scientific information, advertisements, or proposals through direct marketing or newsletters. In this case, Peaberry-up will request your prior consent.

4) Source of Your Personal Data
Personal Data You Provide to Us
You may provide us with personal information about yourself by filling out forms on our website, registering on our site, or contacting us by phone, email, or other means. This includes information you provide when registering to use our site, subscribing to email notifications, subscribing to receive information, participating in an activity, or responding to a survey.
Personal Data We Receive from Other Sources
We may receive personal information about you if you use any of our other websites or services. In this case, we will have informed you at the time of data collection that your data may be shared internally and combined with data collected from other sources.
We also work closely with third parties, including business partners, technical and delivery service subcontractors, advertising networks, and analytics providers, and we may receive personal data about you from them. In this case, these data processors must have informed you at the time of collection that your data may be shared with third parties.

5) Sharing of Personal Data
We will not disclose, sell, or rent your personal information to third parties unless you have previously consented. If you give consent but later change your mind, you can contact us, and we will stop such activity.
We may disclose personal data to the following categories of recipients (only when necessary for them to perform their duties):
• Our staff (including employees and external consultants), professional advisors, and agents;
• Third-party service providers who process your personal data on behalf of Peaberry-up and are contractually obligated to keep your personal data confidential and secure;
• Buyers, or potential buyers, of all or part of Peaberry-up’s business (and their professional advisors) under confidentiality agreements;
• Government agencies, regulatory bodies, and law enforcement authorities where required for the purposes or to protect our legitimate legal interests in compliance with applicable laws.

6) Data Retention
We will delete personal data once it is no longer needed for the purposes described in this privacy policy, unless its retention is required for other essential purposes, including but not limited to legal obligations, claims processing, and dispute resolution.
Generally, data necessary for contract execution is retained for the duration of the contractual relationship with Peaberry-up. It may also be retained:
• For 5 years from the last contact the individual had with Peaberry-up (e.g., a purchase for customers or clicking a hyperlink in an email for prospects);
• After contract execution, in intermediate storage, if required by law (e.g., for accounting or tax obligations) or for evidence in legal disputes, within the applicable statute of limitations.
Inactive accounts for more than five years are automatically deleted.
Under the Sunshine Act, Peaberry-up must retain data related to value transfers for 10 years following their publication on the www.betransparent.be platform.

7) Security
Peaberry-up has implemented appropriate technical and organizational measures to protect the personal information you provide against unauthorized or unlawful processing, accidental destruction, loss, or damage.

8) Your Rights
As a data subject, you have the following rights:
a) the right to access the personal information we hold about you;
b) the right to request that we update or correct any outdated or incorrect personal information we hold about you;
c) when processing is based on your consent, the right to withdraw your consent at any time, without affecting the lawfulness of the processing carried out based on consent before its withdrawal;
d) the right to erasure when the conditions of Article 17 of the GDPR are met;
e) the right to restrict processing when the conditions of Article 18 of the GDPR are met;
f) the right to data portability to the extent that the conditions of Article 20 of the GDPR apply to you;
g) the right to object to the processing of your personal data, to the extent that the conditions of Article 21 of the GDPR are met;
h) the right to lodge a complaint with a supervisory authority; and
i) the right to withdraw your consent to receiving any communications sent for direct marketing purposes that we (with your consent) may send you.
You can exercise these rights at any time by sending us an email at studio@peaberry-up.com.