All data that is directly related to your person or any information that allows for your identification, such as your name, phone number, email address, location, etc. (“Personal Data”).

This Privacy Policy applies to the processing of your Personal Data by Ashton Advisors LLC, with registered office at 10601 Clarence Dr. Suite 250 Frisco, Texas 75033 , United States of America (hereafter: “Ashton Advisors”, “we”, “us”, “our” or derivatives);

Radical Perspective is responsible for the processing of your Personal Data and acts as a data controller, meaning that we determine the purpose and means of the processing of your Personal Data, as described in this Privacy Policy.

We process your Personal Data a.o. when you:

• Fill in the contact form on our Website;

• Request an offer/quote or other information/advice;

• Contact us by phone/email;

• Fill in a job application;

• Conclude an agreement with us.

• Identification- and contact details:

  • Name

  • Address

  • Email address

  • Telephone number

  • Etc.

• Location data if shared

• Professional data

  • Name company

  • VAT / company registration number

  • Professional address

  • Etc.

• Data regarding job-applications

  • Employment details: employer, job title/role, information contained in communications between us and your or your employer;

  • Data provided to us on your curriculum vitae, motivational letter, attachments uploaded by you via a contact form,etc.;

  • Etc.

If you do not provide (certain) Personal Data, it might be possible that we cannot offer our products and/or services or cannot (optimally) provide our services. We will notify you if this is the case.

Ashton Advisors is allowed, under the applicable legislation, to process Personal Data Personal Data when we have a valid processing ground.

When we process your personal data, we will rely on one of the following legal grounds:

• Performance of a contract: when we have a contractual relationship with you (as a supplier, customer, …) (or the intention to enter into a contract with you) processing of your Personal Data might be necessary in order to perform our obligations.

• Legal obligation: we may be under a legal obligation to process and retain certain personal data, such as keeping records for tax purposes, the prevention, monitoring and combating of criminal conduct, crime, fraud and money laundering activities or providing information to a public body or law enforcement agency;

• Legitimate interests: As part of our activities, we may have a so called “legitimate interest” in processing your personal data. In this case, our interests will outweigh your right to privacy. for ex. to provide you with information regarding similar products/services, to answer your questions/concerns, to secure our website, to follow-up on offers/quotes, to contact you regarding future vacancies at the Ashton Advisors, etc.

• Your consent: we may occasionally ask you for specific permission to process some of your personal data, and we will only process your Personal Data in this way if you agree to us doing so. Your consent can always be revoked at any time.

Your Personal Data will be retained diligently by us for as long as required under applicable law or for the fulfilment of the purposes for which it is processed. In any case, we never process your Personal Data for a period longer than is strictly necessary.

We will retain your personal data as follows:

• Newsletter subscriptions: Name, surname, email address and job title will be retained until you unsubscribe.

• Unless a longer retention period is required or justified due to a statute of limitations or compliance with legal obligations, we will delete or anonymize your Personal Data no later than two (2) years after termination of our services/collaboration.

Your Personal Data will not be transferred to third parties outside the Ashton Advisors LLC, except within the framework of the processing activities described above (i.e. external service providers, accountant, lawyer, etc.). Moreover, we may transfer your Personal Data to third parties if we are obliged to do so on the basis of laws and/or regulations, when we are forced to do so as a result of legal proceedings and/or in the event that we consider it necessary to protect our own rights.

Ashton Advisors processes your Personal Data in the European Economic Area (EEA) and outside the EEA. When the Personal Data is transferred from the EEA to a third country, then supplementary measures are in place to guarantee an essentially equivalent level of protection as within the EEA.

We employ reasonable technical and organizational security measures to protect your Personal Data from unlawful or unauthorized access or use, as well as from accidental loss or damage to the integrity of your personal data.

These measures are designed taking into account the potential impact on your privacy, the associated costs and are in accordance with common standard/standards of practice.

Despite the extensive efforts we take, no absolute guarantee can be given for protection against all threats.

If you have any question on how your Personal Data is protected, please contact us (see art. 9).

We value your privacy. This means that you have a number of rights:

• You can at any time request information on how your Personal Data is collected, stored and processed by Ashton Advisors. You have the right to access your Personal Data and the possibility to ask for a correction/rectification in case your Personal Data are wrong. You may receive a copy of the Personal Data that is being processing. The first copy is free of charge, but additional copies may be subject to a reasonable fee.

• You also have the right to request a restriction on the processing of your personal data. You can also withdraw your consent to the processing of your personal data, if given earlier.

• You may also object to the use of your Personal Data for direct marketing purposes or to the sharing of your Personal Data with a third party for the same purposes. Under certain conditions, you may invoke the right to data portability. You will then receive your Personal Data that you have provided to us in a common, structured format and be given the choice to transfer this Personal Data to a third party of your choice.

• You may require us to delete (or anonymize) your personal data, except in a number of cases such as when we are required by law to retain this Personal Data or to prove a transaction.

The above rights can only be exercised in a reasonable manner and in accordance with the limitations of applicable laws or regulations.