Privacy Policy

1. Introduction

The Coating Network ("TCN", "we", "our", or "us") is committed to protecting the privacy and personal data of our users, customers, partners, contractors, and website visitors.

This Privacy Policy explains how we collect, use, store, disclose, and protect personal data when you:

• Visit our website;
• Create or use a TCN account;
• Use our software applications and services;
• Participate in our forums, communities, or learning platforms;
• Communicate with us;
• Interact with our partners and affiliated services.

We process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), applicable Belgian privacy legislation, and other relevant data protection laws.

2. Data Controller

The data controller responsible for the processing of personal data is:

The Coating Network bv (TCN)

Stationsstraat 61A, 8490 Jabbeke, Belgium

privacy@thecoatingnetwork.com

If appointed, the contact details of our Data Protection Officer ("DPO") will be published on our website.

3. Personal Data We Collect

Depending on your interaction with TCN, we may collect the following categories of personal data.

Account Information

• Name
• Employer/company
• Job title
• Email address
• Telephone number
• User account credentials
• Language preferences

Professional Information

• Certifications
• Qualifications
• Industry experience
• Professional memberships
• Training records
• Profile information voluntarily provided

Project and Operational Data

When using TCN software applications, users may upload and create:

• Inspection reports
• QA/QC records
• Project documentation
• Action items
• Meeting minutes
• Audit records
• Photographs
• Comments and communications

Such content may contain personal data where entered by users.

Technical Information

• IP address
• Browser type
• Device information
• Operating system
• Log files
• Date and time of access
• Usage statistics

Marketing and Communication Information

• Newsletter subscriptions
• Event registrations
• Communication preferences
• Customer support interactions

4. How We Collect Data

We collect personal data:

• Directly from you;
• From your employer or organization;
• Through your use of TCN services;
• Through cookies and similar technologies;
• Through integrations authorized by users;
• Through communications with us.

5. Legal Bases for Processing

Under GDPR, we process personal data on one or more of the following legal grounds:

Contractual Necessity

To:

• Create and maintain accounts;
• Deliver software services;
• Provide customer support;
• Manage subscriptions and licensing.

Legitimate Interests

To:

• Improve our services;
• Maintain platform security;
• Prevent fraud;
• Perform system monitoring;
• Develop new features;
• Conduct business analytics.

Consent

Where required, including:

• Marketing communications;
• Certain cookies;
• Optional features.

Legal Obligations

To:

• Comply with applicable laws;
• Meet tax and accounting requirements;
• Respond to lawful requests from authorities.

6. Purposes of Processing

We process personal data to:

• Provide SaaS platform functionality;
• Manage users and organizations;
• Enable collaboration and project workflows;
• Maintain audit trails and compliance records;
• Facilitate communication between users;
• Deliver training and learning services;
• Improve platform functionality;
• Ensure cybersecurity and system integrity;
• Conduct research, analytics, and product development;
• Meet contractual and legal obligations.

7. AI, Analytics and Aggregated Data

TCN may use artificial intelligence, machine learning, and analytics technologies to improve platform functionality and user experience. The platform is intended to support data-driven quality management and industry-wide insights.

Where possible, analytics will be performed on anonymized or aggregated data.

TCN will not use identifiable personal data for automated decision-making that produces legal or similarly significant effects on individuals unless permitted by law and supported by appropriate safeguards.

8. Cookies and Tracking Technologies

Our website may use:

• Essential cookies
• Performance cookies
• Analytics cookies
• Preference cookies
• Marketing cookies

Where legally required, non-essential cookies will only be used after obtaining your consent.

A separate Cookie Policy may provide additional details.

9. Sharing of Personal Data

We may share personal data with:

Service Providers

Including providers of:

• Cloud hosting
• Data storage
• Email delivery
• Security services
• Customer support tools
• Analytics services

Business Partners

Where required to provide services requested by users.

Legal Authorities

Where required by law, court order, or regulatory obligation.

Corporate Transactions

In connection with mergers, acquisitions, investments, restructurings, or asset sales.

We do not sell personal data.

10. International Data Transfers

Where personal data is transferred outside the European Economic Area (EEA), TCN will ensure appropriate safeguards are implemented, including:

• European Commission adequacy decisions;
• Standard Contractual Clauses (SCCs);
• Other lawful transfer mechanisms.

11. Data Security

TCN implements appropriate technical and organizational measures to protect personal data against:

• Unauthorized access;
• Accidental loss;
• Destruction;
• Misuse;
• Alteration;
• Disclosure.

Measures may include:

• Encryption in transit and at rest;
• Access controls;
• Authentication mechanisms;
• Audit logging;
• Network security controls;
• Backup and recovery procedures;
• Security monitoring.

12. Data Retention

We retain personal data only for as long as necessary to:

• Provide services;
• Fulfill contractual obligations;
• Meet legal requirements;
• Resolve disputes;
• Enforce agreements.

Retention periods depend on the type of information and applicable legal obligations.

When retention periods expire, data will be securely deleted, anonymized, or archived in accordance with legal requirements.

13. Your GDPR Rights

Subject to applicable law, you may have the right to:

• Access your personal data;
• Correct inaccurate data;
• Delete your personal data;
• Restrict processing;
• Object to processing;
• Withdraw consent;
• Receive a copy of your data (data portability);
• Lodge a complaint with a supervisory authority.

Requests may be sent to:

privacy@thecoatingnetwork.com

14. Children's Privacy

TCN services are intended for professionals and business users.

We do not knowingly collect personal data from individuals under the age of 16.

15. Third-Party Links

Our website and services may contain links to third-party websites, services, or applications.

We are not responsible for the privacy practices of third parties and encourage users to review their privacy policies.

16. Data Breach Management

In the event of a personal data breach, TCN will investigate the incident and take appropriate steps to mitigate risks.

Where required by GDPR, affected individuals and supervisory authorities will be notified within the legally required timeframes.

17. Supervisory Authority

If you believe your privacy rights have been violated, you may contact:

Belgian Data Protection Authority (Gegevensbeschermingsautoriteit / Autorité de protection des données)

or the supervisory authority in your country of residence.

18. Changes to this Privacy Policy

TCN may update this Privacy Policy periodically to reflect:

• Legal developments;
• Regulatory requirements;
• New platform functionality;
• Operational changes.

Updated versions will be published on this page with a revised "Last Updated" date.

19. Contact Us

For any privacy-related questions, requests, or complaints, please contact:

The Coating Network bv (TCN)

privacy@thecoatingnetwork.com