At Ascending, we care about our Users and Clients security and believe in the need to protect the privacy of the personal information you share with us. We are committed to protect your privacy and ensuring the responsible handling of your personal information. This Privacy Policy outlines our practices concerning the collection, use and disclosure of personal data when you visit our website.

For the purposes of the General Data Protection Regulation (GDPR), users, clients, candidates, whistleblowers, or service providers are hereby informed that personal data provided to us, whether by filling in any form, by e-mail or by any other means, will be processed in accordance with this Personal Data Protection Policy.

We also created a whistleblowing channel in order to report any violation of national and European Union rules identified in Law no. 93/2021 of 20 December, which establishes in Portugal the general regime for the protection of whistleblowers, and transposed Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of European Union law, breaches of Ascending’s internal procedures, policies and regulations, as well as current legal obligations, with an ethical dimension.

The complaint may be submitted anonymously. Without prejudice, in any case, the information contained in the complaint is confidential and protected against unauthorised access.

Data may also be collected from the reported person(s). The privacy information will be communicated to the reported person at the time of the first contact with them, taking into account the confidentiality of the complaint until that time. If the complaint does not contain sufficient elements to proceed with the analysis or is not considered well-founded, no contact will be made with the complainant.

The purpose of this document is to clarify, for the holders of personal data, the data we collect about them, the reason for this collection, as well as the options we provide for the holders of this data to access, rectify or delete the information, among other relevant information and how we proceed with our whistleblowing channel and the protection of whistleblowers.

1. Information Ascending Collects

1.1. Personal Information: Ascending collects data that our visitors, clients, trainees and suppliers voluntarily provide by creating, such as your name and email address or other personal data, when forms are submitted on our website.

1.2. Non-Personal Information: For Ascending, the security and privacy of personal data are of the utmost importance, which is why data is always collected and processed on the basis of the data subject’s consent or when this is necessary for the provision of our services, always with a view to improving them, we collect non-personal information such as your IP address, browser type and browsing patterns.

1.3. Whistleblower Information: Full name, e-mail address, mobile phone number and any other data included in the description of the complaint, if the complaint is not anonymous.

1.4. Denounced Information: The data that the whistleblower indicates in the description of the complaint.

2. Data Processing

Data processing operations are legal when:

a) The processing of personal data is necessary for the performance of a contract;

b) When the data subject has given their consent to the processing of their data;

c) When the processing arises from a legal obligation, including the handling of complaints.

3. How We Use Your Information

3.1 We use the information we collect for the following purposes:

• Optimise the clients visit to our websites.

• Answer to user requests, to send newsletters and information about our services.

• Statistical purposes, browsing data, which will be pseudonymised.

• Providing, maintaining, protecting and improving our services, as well as developing new ones.

• To guarantee the exercise of data subjects’ rights.

• To allow us to offer personalised content, such as newsletters, news, advertisements, and search results that we believe you may like.

• To improve the user’s browsing experience and the overall quality of our services, through the information collected by cookies and other technologies such as pixel tags.

• Processing arising from a legal obligation.

• To guarantee the fulfilment of contracts entered into with Ascending;

• To send periodic emails if you have opted to receive them;

• To comply with legal obligations and protect our rights;

• To comply with the selection of personal data of the whistleblower with the purpose of analysing, forwarding and responding to the complaint, as well as any referral to the competent authorities.

3.2 Ascending will ask for your express consent before using the information for purposes other than those expressly provided for in this Privacy Policy.

3.3 The processing of personal data is necessary for the fulfilment of Ascending’s legal obligations, namely regarding the protection of whistleblowers, the prevention of corruption and the fight against money laundering and terrorist financing. When it comes to reporting violations of Ascending’s internal procedures, policies and regulations, processing is also necessary to pursue Ascending’s legitimate interest in minimising the negative impact resulting from that violation, and to strengthen the culture of compliance with Ascending’s internal policies and procedures.

3.4 The name and e-mail address provided by the whistleblower may also be used to propose surveys to find out their satisfaction with the quality of the whistleblowing management process, based on Ascending’s legitimate interest in obtaining information to analyse and improve the performance, as well as for statistical purposes. The whistleblower has the right to object to these surveys at any time by e-mail or when contacted for this purpose.

4. How Ascending Protects Clients’ Information

Ascending have implemented security measures to safeguard your personal information. We use encryption, secure data storage and access controls to protect your data from unauthorized access, disclosure, alteration and destruction.

5. Your Data Information

5.1 Ascending communicates the information to its commercial partners, subcontractors and service providers who assist us in operating our website or conducting our business.

5.2 To this end, the Users and the Clients gives their consent, and may withdraw it at any time, request the deletion of their data, as well as exercise any of their rights.

5.3 We do not sell or trade your personal information to third parties.

5.4 Personal data may be communicated to the national and European authorities competent to investigate the reported violation, insofar as this is necessary to follow up on the complaint and as is permitted by law.

5.5 Exceptionally, and when strictly necessary for the pursuit of the processing purposes described in this Policy, Ascending may transfer the personal data collected to third countries or international organisations for which there is an adequacy decision by the European Commission or subject to the appropriate safeguards provided by law, such as the conclusion of standard contractual clauses for the transfer of personal data (pursuant to Article 46 of the RGPD). When transferring data to third countries or international organisations on the basis of appropriate safeguards, Ascending will take additional measures to ensure that personal data enjoy a level of protection essentially equivalent to that existing in the European Union.

6. Retention of complaints

Ascending is responsible for receiving and dealing with complaints and therefore has the duty to keep a record of them and preserve them for a minimum of 5 years or for the duration of legal or administrative proceedings relating to them.

7. Your Rights

7.1 You have the right to:

• be informed of how Ascending use and obtain access to your information;

• have your information rectified or erased or to impose limitations on its processing;

• object to the processing of your information, for example for direct marketing purposes or where the processing is based on our legitimate interests;

• have any information you have provided returned to us in an automated form, in a structured, commonly used and machine-readable format, or to have it sent directly to another company, where technically feasible (“data portability”);

• object to any decision based on the automated processing of your personal data, including profiling;

• lodge a complaint with the supervisory authority responsible for data protection issues (for example, in Portugal, the National Data Protection Commission);

• whenever the processing of your information is based on your consent, the right to withdraw consent is subject to legal or contractual restrictions.

7.2 The whistleblower also has the right to lodge a complaint with the National Data Protection Commission (www.cnpd.pt) if they believe that their personal data rights have been infringed.

7.3 The User, the Client and the Whistleblower are warned that, for the execution of orders, the provision of data relating to identity (name, national identity card), address, telephone number and e-mail address will be considered compulsory, since this data is necessary for the formalisation and provision of the services offered by Ascending.

8. Minors

Ascending websites are not designed or intended for use by children under the age of 16. We do not, knowingly, collect any Personal Data on our websites from anyone under the age of 16 without the prior explicit, free, unambiguous and positive consent of a parent or guardian. Parents or guardians may have the right, upon request, to see the information provided by the child and demand that it be deleted. In addition, all minors must obtain the prior consent of their parents or guardians before using or sharing any Personal Data on Ascending websites or any other online source.

9. Cookies

Ascending may use cookies and other similar technologies, which may include pixels, plugins, scripts, tags and device fingerprinting to improve your experience on our website. You can set your browser to disable cookies if you prefer not to use them.

10. Third-Party Links

Ascending website may contain links to third-party websites. We have no control over the privacy practices of these websites and we are not responsible for their policies.

11. Changes to This Privacy Policy

Ascending may update this privacy policy from time to time to reflect changes in our Privacy Policy, so we advise you to read this space regularly, as well as the Terms and Conditions.

12. Contact Information

If you have any questions about this privacy policy, your data or any relatable question to the whistleblowing channel and procedures, please contact us at: info@ascending.ltd.