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Privacy policy

Hello!

We respect your privacy. And that really makes sense. This privacy policy explains how we handle all kinds of data, including your personal data. We explain which of your personal data we store, how we process it and why we do so.

We guarantee that we will treat your personal data confidentially and store it in a highly secure environment. We will not sell your personal data to third parties. Let's be clear about that.

We store and process your personal data in accordance with the rules of the GDPR, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals 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), and national implementing legislation. In this privacy policy, we use specific terms defined in those regulations (e.g., "personal data," "processing," "processor," "controller").

Who are we?

Value Square NV
Schoonzichtstraat 23A
9051 Ghent (Sint-Denijs-Westrem)
Belgium
Company number: BE 0885.750.253.

Value Square is the controller of the personal data it processes. This means that we determine the purpose and means of this processing.

Categories of data processed

Below we indicate the categories of data we process and the purpose of this data processing.

What personal data do we process?

Depending on your relationship with Value Square, we may process the following categories of personal data:

Identification details (name, address, date of birth, national registration number, copy of identity card)
Contact details (email, phone number)
Financial data (account numbers, portfolio information, transactions)
Professional details
Information regarding knowledge and experience (suitability assessment)
Data on sustainability preferences
Communication data (emails, correspondence)
Recording of telephone conversations (if required by law)
Website and usage data (IP address, cookies)

We do not process special categories of personal data, unless required by law (e.g., anti-money laundering legislation).

For what purposes do we process your data?

We process personal data exclusively for specific purposes:

A. Performance of the agreement

Asset management
Investment advice
Client administration
Reporting

Legal basis: performance of a contract (Article 6(1)(b) GDPR)

B. Legal obligations

Anti-money laundering legislation (AML/KYC)
MiFID II obligations
Tax reporting (FATCA, CRS)
Transaction reporting
Retention of communications (MiFID)

Legal basis: legal obligation (Art. 6.1.c GDPR)

C. Legitimate interest

Internal organization
Risk management
IT security
Improvement of services
Dispute management

Legal basis: legitimate interest (Article 6(1)(f) GDPR)

D. Marketing communications

Newsletters
Invitations
Information about services

Legal basis: consent or legitimate interest (for existing clients, in accordance with applicable regulations). You can unsubscribe at any time.

Who do we share your data with?

Your personal data may be shared with:

Custodians (banks/financial institutions)
IT service providers
Cloud providers
Compliance and audit service providers
Marketing platforms
Government agencies and regulators (e.g., FSMA)
Other parties if legally required

We enter into the necessary processing agreements with processors in accordance with Article 28 of the GDPR.

International transfers

In principle, personal data is processed within the European Economic Area (EEA).

For certain marketing communications, Value Square uses Mailchimp (United States).

If personal data is transferred outside the EEA, this will only be done on the basis of appropriate safeguards in accordance with the GDPR, such as:

EU–US Data Privacy Framework (if applicable and to the extent that the relevant service provider is certified under the EU–US Data Privacy Framework), and/or
European Commission Standard Contractual Clauses (SCCs)

How long do we retain your data?

We do not retain personal data longer than necessary for the purpose for which it was collected and in accordance with the statutory retention periods.

Indicative retention periods:

Client files: 10 years after termination of relationship (legal obligation)
AML documentation: 10 years
Telephone recordings (MiFID): in accordance with statutory retention period
Marketing data: until consent is withdrawn or max. 2 years after last contact
Website information: in accordance with cookie policy

Are phone calls recorded?

Phone calls may be recorded:

to comply with MiFID II obligations;
as evidence in the context of financial transactions;
for quality and training purposes.

Recordings are stored for the legally prescribed period.

Legal basis: legal obligation (MiFID II) and legitimate interest.

How do we protect your data?

We take appropriate technical and organizational measures to protect personal data, including:

access restriction based on functions
encryption where appropriate
secure IT systems
logging and monitoring
contractual security obligations for processors

Your rights

You have the following rights:

Right of access
Right to rectification
Right to erasure
Right to restriction of processing
Right to portability
Right to object
Right to withdraw consent
Right to lodge a complaint with the Data Protection Authority

You can exercise your rights via: gdpr@value-square.be

We will respond to your request within one month, subject to extension in accordance with the GDPR.

Right to complain

Questions?

Do you have questions about your privacy, your rights, or how we process your data?

You can contact our Data Protection Officer (DPO) by sending an email to gdpr@value-square.be.

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Complaints?

If you believe that your rights have been violated, you can file a complaint with:

Data Protection Authority
Drukpersstraat 35
1000 Brussels

www.gegevensbeschermingsautoriteit.be

Cookies and website usage

Our website uses cookies and similar technologies to ensure that the website functions correctly, to analyze its use, and—if you give your consent—to enable marketing communications.

11.1 What are cookies?

Cookies are small text files that are stored on your device (computer, tablet, or smartphone) when you visit a website. They allow your device to be recognized on your next visit.

Cookies can be placed by Value Square itself ("first-party cookies") or by third parties ("third-party cookies").

11.2 What types of cookies do we use?

We use the following categories of cookies:

1. Strictly necessary cookies

These cookies are essential for the functioning of the website and cannot be disabled.

Legal basis: legitimate interest (Article 6(1)(f) GDPR)

Examples:

security cookies
session management
language preference

2. Analytical cookies

These cookies help us analyze and improve the use of the website (for example, through statistics on visitor numbers and surfing behavior).

If these cookies process personal data, they will only be placed after you have given your consent.

Legal basis: consent (Art. 6.1.a GDPR)

3. Marketing cookies (if applicable)

These cookies may be used to show you relevant information or advertisements via external platforms or to measure the effectiveness of campaigns.

Legal basis: consent (Art. 6.1.a GDPR)

11.3 Third parties

If we use external service providers (for example, for website analysis or newsletters), these third parties may place cookies via our website.

When personal data is transferred outside the European Economic Area, this is done exclusively on the basis of appropriate safeguards in accordance with the GDPR (e.g., EU–US Data Privacy Framework or standard contractual clauses).

11.4 Your consent and management of cookies

When you visit our website for the first time, a cookie banner will ask you to set your preferences.

You can:

accept all cookies;
only keep necessary cookies;
adjust your preferences.

You can withdraw or change your consent at any time via the cookie settings on our website.

You can also manage or delete cookies via your internet browser settings.

11.5 Retention periods

Cookies are not stored longer than necessary for the purpose for which they were placed. The maximum storage period is 13 months, unless a shorter period applies.

Changes

Value Square may amend this privacy statement from time to time. The most recent version is always available on the website.

Last update: February 18, 2026