Privacy Policy.

1. Who We Are

PCD Investment Partners B.V., operating under the name PCD CareHub (hereinafter: "PCD", "we", "us", or "our"), is the data controller for the processing of personal data as described in this privacy policy. We are registered with the Chamber of Commerce under number 97139572 and located at the following address:

PCD Investment Partners B.V. (t/a PCD CareHub)
Lijndonk 4
4825 BG Breda, The Netherlands
Phone: +31 6 53 85 27 53

Scope: this privacy policy applies to the public website of PCD CareHub and to our private investor portal. Both environments fall under the same data controller: PCD Investment Partners B.V., operating under the name PCD CareHub. When you navigate from this website to the investor portal, this policy continues to apply to the processing of your personal data; only the technical environment changes.

2. What Data We Collect

We may collect and process the following personal data:

• Contact form data: name, email address, phone number, company name, and the message you submit via our contact form.
• Server logs: our hosting provider records standard technical logs per request (anonymized IP address, browser type, page visited, date and time). These logs are used solely for security and debugging purposes.
• Anonymized usage data: via Vercel Web Analytics we collect cookieless page statistics (number of page views, referrer, country, device type). No cookies are placed and no personal data is processed. The data is aggregated and cannot be traced back to individual visitors.
• Cookie data: information collected via cookies and similar technologies. See our cookie policy for more information.
• Communication data: data you provide when you communicate with us by email, phone, or other means.
• Investor portal data: if you use our investor portal, we process additional data such as your account information (name, email address), KYC verification data (identity documents, verification status), and correspondence submitted via the complaints form.

3. Why We Collect This Data

We process your personal data for the following purposes:

• Responding to inquiries: to answer your questions, requests, or applications and to communicate with you about our services.
• Security and debugging: to keep our website secure and stable and to identify errors via anonymized server logs.
• Legal obligations: to comply with legal obligations incumbent upon us, such as fiscal retention requirements and record-keeping obligations.
• Legitimate interest: to optimize our services, prevent fraud, and ensure the security of our website.
• Investor portal: to manage your account, perform KYC verification, inform you of your account status, and handle complaints via transactional emails.

4. How Long We Retain Data

We do not retain your personal data longer than is strictly necessary for the purposes for which it is collected. We apply the following retention periods:

• Contact form data: a maximum of 12 months after the last contact, unless longer retention is necessary for an ongoing engagement.
• Server logs: a maximum of 30 days on a rolling basis, solely for security and debugging purposes.
• Investor portal data: for the duration of your account and a maximum of 12 months after termination, unless a longer retention period is required by law.
• Legally required data: in accordance with statutory retention periods, such as 7 years for fiscal data.

5. Sharing with Third Parties

PCD CareHub does not sell your personal data to third parties. We share your data with third parties only where necessary for the provision of our services or to comply with a legal obligation. We enter into data processing agreements with organizations that process your data on our behalf to ensure the same level of security and confidentiality of your data.

Examples of third parties we work with:

• Vercel (Vercel Inc., United States) as the hosting provider for our website and for anonymized usage statistics via Vercel Web Analytics. When you visit our website, your IP address is processed by Vercel's edge servers. Where possible, requests are handled from edge locations within the EU. Vercel Web Analytics places no cookies and processes no personal data; the statistics are aggregated and cannot be traced back to individual visitors. The transfer of data is safeguarded on the basis of the EU-US Data Privacy Framework.
• Supabase (Supabase, Inc., United States) as the hosting and database provider for our investor portal. Supabase processes and stores account data, KYC data, and documents. The servers are located in the EU (AWS eu-west-1). The transfer to Supabase, Inc. is safeguarded on the basis of Standard Contractual Clauses (SCCs) pursuant to Article 46(2) GDPR.
• Resend (Resend, Inc., United States) as the email service provider for sending transactional emails from our investor portal, such as invitations, welcome messages, KYC status notifications, account notifications, and complaint confirmations. Resend processes your email address and name for this purpose. The transfer is safeguarded on the basis of Standard Contractual Clauses (SCCs) pursuant to Article 46(2) GDPR.

6. Your Rights

Under the General Data Protection Regulation (GDPR), you have the following rights with respect to your personal data:

• Right of access: you may request an overview of the personal data we process about you.
• Right to rectification: you may request that we correct inaccurate or incomplete data.
• Right to erasure: you may request that we delete your personal data.
• Right to restriction of processing: you may request that we (temporarily) restrict the processing of your data.
• Right to object: you may object to the processing of your personal data on the basis of our legitimate interest.
• Right to data portability: you may request that we transfer your data to you or another organization in a structured, commonly used, and machine-readable format.

Would you like to exercise any of these rights? Please contact us using the contact details at the bottom of this page. We will respond to your request as soon as possible, and within four weeks at the latest. You also have the right at any time to file a complaint with the Dutch Data Protection Authority (www.autoriteitpersoonsgegevens.nl).

7. Security

PCD CareHub takes the protection of your personal data seriously and implements appropriate technical and organizational measures to prevent misuse, loss, unauthorized access, unwanted disclosure, and unauthorized alteration. Our security measures are based on the principles of NEN 7510 and ISO 27001, including:

• SSL/TLS encryption for all data transmission via our website.
• Regular security updates and patches.
• Access controls and restricted authorization for employees.
• Periodic security audits and risk assessments.
• Data processing agreements with all processors.

Should you nonetheless have the impression that your data is not adequately secured or that there are indications of misuse, please contact us.

8. Cookies

Our website uses cookies. A cookie is a small text file that is stored in the browser of your computer, tablet, or smartphone upon your first visit to our website. For more information about which cookies we use, for what purposes, and how you can manage them, please refer to our comprehensive cookie policy.

Investor portal: when you navigate from this website to the private investor portal, functional session cookies are placed there by our authentication provider Supabase. These cookies are strictly necessary for logging in and maintaining the security of your session and are exempt from consent requirements under Article 11.7a(3) of the Telecommunications Act (ePrivacy). No analytical or marketing cookies are placed. See the cookie policy for the complete overview.

9. Changes to This Privacy Policy

PCD CareHub reserves the right to amend this privacy policy. Changes will be published on this page. We recommend that you consult this privacy policy regularly so that you are aware of any changes. Material changes will be clearly communicated on our website.

10. Contact

Do you have questions about this privacy policy or about how we handle your personal data? Please do not hesitate to contact us:

PCD CareHub
Lijndonk 4, 4825 BG Breda, The Netherlands
Phone: +31 6 53 85 27 53

You may also use our contact form. We aim to respond to your request within two business days.