PRIVACY POLICY

INFORMATION FOR INTERESTED PARTIES, CLIENTS AND BUSINESS (WEBSITE AND CORRESPONDENCE)

regarding the processing of personal data according to Art. 13 General Data Protection Regulation

Date: 24 June 2026

RESPONSIBLE PERSON

Responsible for the processing of personal data are:

TWS Partners AG, Gollierstr. 4, 80339 Munich, Germany, Tel: +49 (0) 89 / 2000 40 0 | info@tws-partners.com

TWS Partners Limited, 2 Eastbourne Terrace, London W2 6LG, United Kingdom, Tel: +49 (0) 89 / 2000 40 0 | info@tws-partners.com

TWS Partners B.V., Vliegend Hertlaan 21, 3526 KT Utrecht, Netherlands | info@tws-partners.com

TWS Partners CH GmbH, Churerstrasse 54, 8808 Pfäffikon SZ, Switzerland | info@tws-partners.ch

(in the following stated as TWS Partners)

Represented by Marcus Schreiber, Dr. Andreas Engel, Dr. Alexander Klein, Dr. Sebastian Moritz

DATA PROTECTION OFFICER

You can reach our data protection officer at: Syngenity GmbH, datenschutz@tws-partners.com

PRIVACY STATEMENT

This privacy policy applies both to the use of our website and to the processing of personal data in the context of our correspondence and communication with clients, prospective clients and business contacts (for example by e-mail).

To us, protection and security of your data and your privacy are a top priority. We only collect personal information to a limited extent and, where necessary, for:

• Providing our services
• Contract performance (including initiation, conclusion, fulfilment and termination of a contract)
• Processing and answering of inquiries (contact form, download form and e-mail correspondence)
• Secure operation
• Improvement of our offers
• Prevention, detection and investigation of potentially prohibited or illegal activities

We treat your personal data confidential and according to the relevant data protection regulations as well as this privacy policy. Using our website is normally possible without providing personal data. Collecting personal data (e.g. name, e-mail-address, address) only happens on a voluntary basis. This data will be used by TWS Partners AG, TWS Partners Limited, TWS Partners B.V. and TWS Partners CH GmbH. It will not be transmitted to further third parties without consent. We assure to make all necessary technical and organizational efforts to protect your data. We would like to make you aware that online data transmission (e.g. communication via e-mail) can exhibit security gaps. A complete protection of data from access through third parties is not possible.

PURPOSES OF PROCESSING AND LEGAL BASIS

Personal data is processed for the provision of our website. For detection and defence against attacks we store the IP addresses.

We consider visiting our website as performance of the contract. The legal basis of processing is Art. 6 Par. 1 letter b and f General Data Protection Regulation.

Where we correspond with you (for example by e-mail) in connection with inquiries, offers or client projects, we process your contact details and the content of your communication on the basis of Art. 6 para. 1 lit. b and f GDPR.

TYPES OF DATA AND AFFECTED PEOPLE

This personal data of visitors of this website (affected people) is processed: IP-address, time, browser-type/-version, operating system, referrer URL (the previously visited page), cookies.

COOKIES

This website partly uses cookies. Cookies do not harm your computer and do not contain viruses. Cookies serve to make our offer more user-friendly. You can adjust your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies generally, and activate the automatic deletion of cookies when closing the browser. Deactivating cookies may limit the functionality of this website.

SERVER-LOG-FILES

Server-side log files are only stored in an anonymous form.

THIRD COUNTRY

Opening a website cannot guarantee that the data will remain within the EU. Where applicable, it might be technically possible, due to the operating principles of the Internet, that a request while being in transit to us or vice versa is redirected via a server in an insecure third country. This cannot be prevented either.

DURATION OF DATA RETENTION

We store IP addresses of a website visit for 7 days.

For correspondence and client communication, we retain your personal data for as long as is necessary to fulfil the purpose for which it was collected. The criteria used to determine our retention periods include:

• the length of our ongoing relationship with you and the provision of our services, and the period thereafter during which we may have a legitimate need to reference your personal data to address issues that may arise;
• whether we are subject to a legal obligation (for example, tax or commercial law may require us to keep records of transactions for a certain period before they can be deleted); and
• whether retention is advisable in light of our legal position (for example, applicable statutes of limitations, litigation or regulatory investigations).

USE OF ARTIFICIAL INTELLIGENCE (AI) TO PROCESS INQUIRIES AND CORRESPONDENCE

To process inquiries efficiently and to support our internal workflows, we use AI-based assistance systems. In this context, content from our correspondence with you (such as contact details and the content of your messages) may be processed by these systems.

1. ChatGPT (OpenAI). We use ChatGPT (Business version). Provider is OpenAI Ireland Ltd., 1st Floor, The Academy, 42 Pearse Street, Dublin 2, Ireland. Personal data (such as name, e-mail address, company) and the content of your message may be transmitted to OpenAI and processed there in order to structure inquiries, prepare answers or summarise matters. The legal basis is Art. 6 para. 1 lit. f GDPR (legitimate interest in the efficient, fast and high-quality handling of inquiries). We have concluded a data processing agreement pursuant to Art. 28 GDPR with OpenAI. Under the business tariff, the data we enter is not used to train OpenAI’s models. A transfer to the parent company in the USA cannot be excluded; this transfer is safeguarded by the EU-US Data Privacy Framework and EU standard contractual clauses (SCCs).
2. Claude (Anthropic). Alternatively or in addition we use Claude (Team version). Provider is Anthropic, PBC, 548 Market Street, PMB 92256, San Francisco, California 94104, USA. Your contact details and the content provided may likewise be transmitted to and processed by Anthropic. The legal basis is Art. 6 para. 1 lit. f GDPR. We have concluded a data processing addendum pursuant to Art. 28 GDPR with Anthropic. Under the business tariffs used, data is processed strictly on our instructions and is not used to train Anthropic’s models. As Anthropic is based in the USA, a third-country transfer takes place; to ensure an adequate level of protection we have concluded EU standard contractual clauses (SCCs) with Anthropic, and Anthropic is also certified under the EU-US Data Privacy Framework.

RIGHT TO ACCESS, CORRECTION, DELETION, RESTRICTION, DATA PORTABILITY

As we separate your IP address from the rest of the data immediately after visiting the website, we cannot provide you with meaningful information about this. Correction, deletion, restriction and data portability are accordingly not applicable to that website data. In relation to personal data processed in the context of our correspondence with you, you may exercise your rights of access, correction, deletion, restriction, objection and data portability by contacting us using the details above.

GOOGLE ANALYTICS

This website uses functions of the web analysis service Google Analytics. We only use Google Analytics if you have previously given us your express consent. The provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses cookies, which are text files stored on your computer that enable an analysis of your use of the website. The information generated is usually transferred to a Google server in the United States and stored there. We have activated IP anonymization on this website, so your IP address is abbreviated by Google within the EU/EEA prior to transmission to the United States. We have executed a contract data processing agreement with Google. You can prevent the recording of cookie-generated data by installing the browser plug-in available at tools.google.com/dlpage/gaoptout, or object to data collection via the opt-out cookie. For more information see Google’s data privacy declaration at support.google.com/analytics/answer/6004245.

RIGHT TO APPEAL

If you are dissatisfied, please let us know using the above contact details. You also have the right to complain to a supervisory authority. The authority responsible for TWS Partners AG: Bayerisches Landesamt für Datenschutzaufsicht, Postfach 606, 91511 Ansbach, Germany, Tel: +49 (0) 981 53 1300, poststelle@lda.bayern.de, https://www.lda.bayern.de. The authority responsible for TWS Partners Limited: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, England, Tel: +44 1625 545 700, https://ico.org.uk/.

PROVISION OF YOUR DATA

You initiate every website request, so you provide us with the above-mentioned data. Your IP address is required, otherwise we cannot display our website.

AUTOMATED DECISION

There is no automated decision. The AI assistance systems described above are used to support our staff; they do not make automated decisions producing legal effects concerning you or similarly significantly affecting you within the meaning of Art. 22 GDPR.