Versio B.V. | Personal data exchange policy
Version 1.0 | June 2021

This policy on the exchange of personal data has been drawn up by Versio B.V. (Total WebhostingSolutions), whereas Total Webhosting Solutions exchanges personal data with its Business Units(BUs). Both Total Webhosting Solutions and every individual BU can be considered a controller within
the meaning of Article 4(7) of the GDPR. Within the framework of the careful handling of personaldata, Total Webhosting Solutions has laid down a number of arrangements regarding the exchange ofpersonal data with its BUs in this policy.
1. The personal data exchanged will be handled in accordance with the applicable laws andregulations on the protection of personal data. Every individual BU is independently responsible
for compliance with the applicable laws and regulations.
2. The personal data exchanged will only be used for the purpose for which these were exchanged.
3. The personal data exchanged will only be made available internally to those employees who
require these personal data in the discharge of their duties.
4. The personal data exchanged will be treated confidentially.
5. Total Webhosting Solutions and the BUs are each independently responsible for the security ofthe personal data that fall under their responsibility.
6. Total Webhosting Solutions and the BUs will independently inform data subjects of the purposes
for which personal data are processed in their own privacy statement and will refrain fromprocessing the personal data for any purpose other than the purpose for which they themselves
have a legitimate basis.
7. Total Webhosting Solutions and the BUs are and will remain independently responsible forreporting a personal data-related breach (data breach) within the meaning of Article 4(12) of theGDPR to the Dutch Data Protection Authority and/or data subjects. If the data breach pertains toa situation in which Total Webhosting Solutions can be considered to be a joint controller, theparties will consult as soon as possible to determine how the data breach can be dealt with as
carefully and adequately as possible.
8. In the event that a data subject sends a request to exercise their rights – such as the right ofinspection, deletion, rectification or objection, or any of the other rights referred to in the GDPR –to a BU, the BU will handle the request independently if the request relates to processing withregard to which the relevant BU is an independent controller.
9. If the request (as described under 8) pertains to processing with regard to which the BU and Total
Webhosting Solutions are both considered controllers, the parties will consult as soon as possible

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to determine who will handle the request. The data subject who submitted the request may be
informed of this.
10. Where necessary, the BU will provide any information and assistance that may be required toenable Total Webhosting Solutions to handle the request (as described under 9). Total
Webhosting Solutions will have the same obligation towards the BU.
11. If the data subject sends their request to a BU and the request pertains to another BU, or to Total
Webhosting Solutions, the BU will ensure that the request is sent to the correct BU or to Total
Webhosting Solutions. Total Webhosting Solutions will have the same obligation towards theBUs.

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