Privacy Policy.

PRIVACY POLICY

TRIVIAN B.V.

Trivian B.V. | 254 Boeing Avenue | 1119 PZ Schiphol-Rijk

Chamber of Commerce: 97569267 | VAT: NL868115812B01

Email: info@trivian.nl | Phone: 085 – 760 81 85 | www.trivian.nl

Version: 2026-01 | Effective as of: June 19, 2026

This privacy statement describes how Trivian B.V. processes personal data in connection with its training services.

The complete and up-to-date version can be found at www.trivian.nl/privacybeleid.

Article C1 — Data Controller

Trivian B.V. is the data controller within the meaning of the General Data Protection Regulation (GDPR).

Article C2 — What Data Do We Process

Trivian processes the following categories of personal data:

• Personal details and contact information (name, email, phone number, address)
• Date of Birth and Identification Information (for Admission and Certification)
• Progress data, test results, and certificates
• Payment information (via a secure payment provider; Trivian does not store full payment card details)
• Login credentials and user activity on the learning platform and in lab environments
• IP addresses and website behavior (via cookies — see the cookie policy at www.trivian.nl)
• Communication data (email, messages, call logs), to the extent relevant to the performance of the agreement

Article C3 — Principles and Objectives

Trivian processes personal data solely on the basis of one of the following legal grounds:

• Implementation of the agreement — including registration, intake, delivery of the training, guidance, certification support, and administration
• Legal obligation — regarding invoicing, record-keeping requirements, and reports to competent authorities
• Legitimate interest — for quality improvement, securing the learning platform, tracking activities in labs, and fraud prevention
• Consent — for marketing communications, the use of testimonials, photos, or videos, and other processing activities for which consent has been requested

Personal data will not be processed for purposes other than those for which it was collected, unless this is permitted by law or the data subject has given consent.

Article C4 — Retention Periods

Trivian does not retain personal data for longer than is necessary for the purpose for which it was collected, unless a longer retention period is required by law.

Article C5 — Sharing with Third Parties

Trivian shares personal data with third parties only to the extent necessary for the delivery of the training program or as required by law. Trivian enters into a data processing agreement with all data processors in accordance with the GDPR.

Data may be shared with:

• Instructors, trainers, and mentors involved in the program
• IT service providers and learning platform vendors
• Payment providers (payment-related data only)
• External certifying bodies (e.g., CompTIA, EC-Council, ISC2, ISACA) for exam registration
• Government agencies and regulatory authorities, if required by law
• Accountants and legal advisors, subject to strict confidentiality obligations

Personal data is never sold to third parties or shared for third-party commercial purposes.

Article C6 — Your Rights

Under the GDPR, you have the following rights regarding your personal data:

• Right of access — you can request information about what personal data we process about you
• Right to rectification — you can have inaccurate information corrected
• Right to erasure (“right to be forgotten”) — you may request that your data be erased, provided that no legal retention requirement applies
• Right to restriction of processing — you may request that processing be temporarily restricted
• Right to data portability — you can request your data in a structured, commonly used format
• Right to Object — You may object to processing based on legitimate interests
• Right to Withdraw Consent — You may withdraw your consent at any time, without affecting the lawfulness of processing prior to the withdrawal

Please send requests to info@trivian.nl. Trivian will respond within 1 month. In the case of complex or multiple requests, this period may be extended by up to 2 months; Trivian will notify you of this in a timely manner.

You also have the right to file a complaint with the Dutch Data Protection Authority via autoriteitpersoonsgegevens.nl.

Article C7 — Security

Trivian implements appropriate technical and organizational security measures to protect personal data against loss, unauthorized access, disclosure, or misuse. These measures include, among others:

• Encryption of data in transit and at rest
• Access control based on the “need-to-know” principle
• Periodic security audits and penetration tests
• Logging and Monitoring of Access to Personal Data
• Awareness Training for Employees

In the event of a data breach that may pose risks to data subjects, the Dutch Data Protection Authority will be notified within 72 hours, in accordance with the GDPR. Data subjects will be informed if the data breach is likely to pose a high risk to their rights and freedoms.

Article C8 — International Transfer

In principle, personal data is processed within the European Economic Area (EEA). If service providers outside the EEA are used, data is transferred solely on the basis of appropriate safeguards in accordance with the GDPR, such as:

• Standard Contractual Clauses approved by the European Commission
• An adequacy decision by the European Commission for the country in question
• Binding Corporate Rules (BCR)

Upon request, Trivian will provide information about the specific safeguards that apply to a data transfer.

Article C9 — Cookies

Trivian uses cookies on its website and learning platform. An overview of the cookies used, their purpose, and retention periods is included in the cookie policy at www.trivian.nl/cookies. Functional cookies are necessary for using the learning platform and cannot be disabled. Your consent is requested for other cookies.

Article C10 — Amendments

Trivian may amend this privacy statement at any time. The most current version can be found at www.trivian.nl/privacybeleid. In the event of material changes, data subjects will be actively notified, provided Trivian has their contact information.

Do you have questions about your privacy?

Trivian B.V.

254 Boeing Avenue | 1119 PZ Schiphol-Rijk

Chamber of Commerce: 97569267 | VAT: NL868115812B01

info@trivian.nl | 085 – 760 81 85 | www.trivian.nl

Version 2026-01 | Effective June 19, 2026