Data Protection Statement

Version effective as of 23.07.2026

Data Protection Statement of Lighthouse Bay Solutions

With this Data Protection Statement Lighthouse Bay Solutions (thereafter occasionally abbreviated with “LHBS”) describes how it collects and further processes personal data. This Data Protection Statement is not necessarily a comprehensive description of our data processing. It is possible that other data protection statements are applicable to specific circumstances. The term “personal data” in this Data Protection Statement shall mean any information that identifies, or could reasonably be used to identify any person. If you provide us with personal data of other persons (such as family members, work colleagues), please make sure the respective persons are aware of this Data Protection Statement and only provide us with their data if you are allowed to do so and such personal data is correct. This Privacy Notice is aligned with the EU General Data Protection Regulation («GDPR»). However, the application of this laws depends per individual case.

Representative. The Controller of data processing as described in this data protection statement (i.e. the responsible person) is Lighthouse Bay Solutions, Dr. Sebastian Rath, 212 GK Haarlem, the Netherlands. You can notify us of any data protection related concerns using the following contact details: https://www.lighthousebaysolutions.com/contact/ You can contact the data protection officer pursuant to art. 37 GDPR using the following contact details: s.rath@lighthousebaysolutions.com, who additionally is our representative in the EEA according to article 27 GDPR.

Collection and Processing of Personal Data. Lighthouse Bay Solutions primarily process personal data obtained from our clients and other business partners as well as other individuals in the context of our business relationships with them or that is collected from users when operating our websites, apps and other applications. Insofar as it is permitted to LHBS obtains certain personal data from publicly accessible sources (e.g., debt registers, land registries, commercial registers, press, internet) or may receive such information from affiliated companies, from authorities or other third parties. Apart from data you provided to us directly, the categories of data received about you from third parties include, but are not limited to, information from public registers, data received in connection with administrative or court proceedings, information in connection with your professional role and activities (e.g., in order to conclude and carry out contracts with your employer), information about you in correspondence and discussions with third parties, credit rating information (if conducting business activities with you personally), information about you given to us by individuals associated with you (family, consultants, legal representatives, etc.) in order to conclude or process contracts with you or with your involvement (e.g. references, your delivery-address, powers of attorney), information regarding legal regulations such as anti-money laundering and export restrictions, bank details, information regarding insurances, our distributors and other business partners for the purpose of ordering or delivering services to you or by you (e.g., payments made, previous purchases), information about you found in the media or internet (insofar as indicated in the specific case, e.g. in connection with job applications, media reviews, marketing/sales, etc.), your address and any interests and other socio-demographic data (for marketing purposes), data in connection with your use of our websites (e.g., IP address, MAC address of your smartphone or computers, information regarding your device and settings, cookies, date and time of your visit, sites and content retrieved, applications used, referring website, localization data).

Purpose of Data Processing and Legal Grounds. Lighthouse Bay Solutions primarily uses collected data in order to conclude and process contracts with our clients and business partners, in particular in connection with advisory services to our clients and the procurement of products and services from our suppliers and subcontractors, as well as in order to comply with our domestic and foreign legal obligations. You may be affected by our data processing in your capacity as an employee of such a client or business partner. In addition, in line with applicable law and where appropriate, LHBS may process your personal data for a variety of legitimate purposes, such as:

providing and developing our products, services and websites, apps and other platforms, on which being active;
communication with third parties and processing of their requests (e.g., job applications, media inquiries);
review and optimization of procedures regarding needs assessment for the purpose of direct customer approach as well as obtaining personal data from publicly accessible sources for customer acquisition;
advertisement and marketing (including organizing events), provided that you have not objected to the use of your data for this purpose (if you are part of our customer base and you receive our advertisement, you may object at any time and LHBS will place you on a blacklist against further advertising mailings);
market and opinion research, media surveillance;
asserting legal claims and defense in legal disputes and official proceedings;
prevention and investigation of criminal offences and other misconduct (e.g. conducting internal investigations, data analysis to combat fraud);
ensuring our operation, including our IT, our websites, apps and other appliances;
video surveillance to protect our domiciliary rights and other measures to ensure the safety of our premises and facilities as well as protection of our employees and other individuals and assets owner by or entrusted to us (such as e.g. access controls, visitor logs, network and mail scanners, telephone recordings);
acquisition and sale of business divisions, companies or parts of companies and other corporate transactions and the transfer of personal data related thereto as well as measures for business management and compliance with legal and regulatory obligations as well as internal regulations of LHBS.

If you have given us your consent to process your personal data for certain purposes (for example when registering to receive newsletters or carrying out a background check), LHBS will process your personal data within the scope of and based on this consent, unless having another legal basis, provided that one is required. Consent given can be withdrawn at any time, but this does not affect data processed prior to withdrawal.

Cookies / Tracking and Other Techniques Regarding the Use of the Lighthouse Bay Solutions Website. If permanent Cookies or other tracking techniques are used (text to be amended according to the specific case): LHBS typically uses “cookies” and similar techniques on our websites [and apps], which allow for an identification of your browser or device. A cookie is a small text file that is sent to your computer and automatically saved by the web browser on your computer or mobile device, when you visit our website [or install our app]. If you revisit our website [or use our app], LHBS may recognize you, even without knowing your identity. Besides cookies that are only used during a session and deleted after your visit of the website (“session cookies”), the website may use cookies in order to save user configurations and other information for a certain time period (e.g., two years) (“permanent cookies”). Notwithstanding the foregoing, you may configure your browser settings in a way that it rejects cookies, only saves them for one session or deletes them prematurely. Most browsers are preset to accept cookies. LHBS use permanent cookies in order to understand how you use our services and content, and to enable to show you customized offers and advertisement (which may also happen on websites of other companies; should your identity be known to us, such companies will not learn your identity from us; they will only know that the same user is visiting their website has previously visited a certain website). If you block cookies, it is possible that certain functions (such as, e.g., language settings, shopping basket, ordering processes) are no longer available to you. In accordance with applicable law, LHBS may include visible and invisible image files in our newsletters and other marketing e-mails, now or in the future. If such image files are retrieved from our servers, it is possible to determine whether and when you have opened the e-mail, in order to measure and better understand how you use our offers and customize them. You may disable this in your e-mail program, which will usually be a default setting.

Data Transfer and Transfer of Data Abroad. In the context of business activities and in line with the purposes of the data processing set out above, LHBS may transfer data to third parties, insofar as such a transfer is permitted and deemed appropriate, e.g. in order for data processing or own purposes. In particular, the following categories of recipients may be concerned:

Service providers (within LHBS or externally, such as e.g. business partners, collaboration platforms), including processors (such as e.g. IT providers);
Dealers, suppliers, subcontractors, and other business partners;
Clients;
Domestic and foreign authorities or courts;
The media;
The public, including users of our websites and social media;
Competitors, industry organizations, associations, organizations, and other bodies;
Acquirers or parties interested in the acquisition of business divisions, companies, or other parts of LHBS;
Other parties in possible or pending legal proceedings;
Affiliates of LHBS.

Together, Recipients. Certain Recipients may be within Europe, but they may be located in any country worldwide. In particular, you must anticipate your data to be transmitted to any country in which LHBS is represented by affiliates, branches, or other offices as well as to other countries in Europe and the USA where service providers are located (such as Microsoft). If a recipient is located in a country without adequate statutory data protection, LHBS requires the recipient to undertake to comply with data protection (for this purpose, LHBS uses the revised European Commission’s standard contractual clauses, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj), unless the recipient is subject to a legally accepted set of rules to ensure data protection and unless LHBS cannot rely on an exception. An exception may apply, for example, in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented, or if data has been made available generally by you and you have not objected against the processing.

Your Rights. In accordance with and as far as provided by applicable law, you have the right to access, rectification, and erasure of your personal data, as well as the right to object to our data processing. Please contact us to exercise these rights at: https://www.lighthousebaysolutions.com/contact/

Retention Periods for your Personal Data. Lighthouse Bay Solutions processes and retains your personal data as long as required for the performance of our contractual obligation and compliance with legal obligations or other purposes pursued with the processing, i.e. for the duration of the entire business relationship (from the initiation, during the performance of the contract until it is terminated) as well as beyond this duration in accordance with legal retention and documentation obligations. Personal data may be retained for the period during which claims can be asserted against our company or insofar as being otherwise legally obliged to do so or if legitimate business interests require further retention (e.g., for evidence and documentation purposes). As soon as your personal data are no longer required for the above-mentioned purposes, they will be deleted or anonymized, to the extent possible. In general, shorter retention periods of no more than twelve months apply for operational data (e.g., system logs).

Data Security. Lighthouse Bay Solutions takes and relies on appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse such as IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions.

Obligation to Provide Personal Data To Us. In the context of our business relationship you must provide us with any personal data that is necessary for the conclusion and performance of a business relationship and the performance of our contractual obligations (as a rule, there is no statutory requirement to provide us with data). Without this information, LHBS will usually not be able to enter into or carry out a contract with you (or the entity or person you represent). In addition, the website cannot be used unless certain information is disclosed to enable data traffic (e.g. IP address). Profiling [and Automated Individual Decision-Making] LHBS may partially process your personal data automatically with the aim of evaluating certain personal aspects (profiling). In particular, profiling allows us to inform and advise you about products possibly relevant for you more accurately. For this purpose, LHBS may use evaluation tools that enable us to communicate with you and advertise you as required, including market and opinion research. [In establishing and carrying out a business relationship, LHBS generally do not use any fully automated individual decision-making (such as pursuant to article 22 GDPR). Should LHBS use such procedures in certain cases, you shall be informed separately on this and advise you of your relevant rights if required by law.]

Your Rights. In accordance with and as far as provided by applicable law (as is the case where the GDPR is applicable), you have the right to access, rectification and erasure of your personal data, the right to restriction of processing or to object to our data processing, in particular for direct marketing purposes, for profiling carried out for direct marketing purposes and for other legitimate interests in processing in addition to right to receive certain personal data for transfer to another controller (data portability). Please note, however, that LHBS reserve the right to enforce statutory restrictions on our part, for example if being obliged to retain or process certain data, having an overriding interest (insofar as LHBS may invoke such interests) or needing the data for asserting claims. If exercising certain rights will incur costs on you, LHBS will notify you thereof in advance. LHBS have already informed you of the possibility to withdraw consent. Please further note that the exercise of these rights may be in conflict with your contractual obligations and this may result in consequences such as premature contract termination or involve costs. If this is the case, LHBS will inform you in advance unless it has already been contractually agreed upon. In general, exercising these rights requires that you are able to prove your identity (e.g., by a copy of identification documents where your identity is not evident otherwise or can be verified in another way). In order to assert these rights, please contact us at the addresses provided in Section 1 above. In addition, every data subject has the right to enforce his/her rights in court or to lodge a complaint with the competent data protection authority. The competent data protection authority of the Netherlands is the Dutch Data Protection Authority (Dutch: Autoriteit Persoonsgegevens or AP): https://www.autoriteitpersoonsgegevens.nl/en

Amendments of this Data Protection Statement. Lighthouse Bay Solutions may amend this Data Protection Statement at any time without prior notice. The current version published on our website shall apply. If the Data Protection Statement is part of an agreement with you, LBHS will notify you by e-mail or other appropriate means in case of an amendment.

For further inquiries, please contact Lighthouse Bay Solutions at: https://www.lighthousebaysolutions.com/contact/