Privacy Policy

1. Introduction

Estera Group respects the privacy of everyone who visits its website. This Privacy Policy explains how we process personal data in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation, GDPR) and applicable Belgian legislation.

It applies to visitors to esteragroup.eu and to anyone who contacts Estera Group, Estera Capital or Estera Strategic Advisory through this website.

2. Data Controller

The data controller is: Estera Group [To be confirmed: full legal entity name and legal form] [To be confirmed: registered office] [To be confirmed: Belgian enterprise number / VAT number] Website: www.esteragroup.eu Email: fg@esteragroup.eu · edn@esteragroup.eu

Contact locations in Belgium: Antwerp — Napelsstraat 73, 2000 Antwerp, Belgium Knokke — Sparrendreef 83A, 8300 Knokke, Belgium

[To be confirmed: whether Estera Capital and Estera Strategic Advisory are separate legal entities and, if so, which entity is responsible for which processing.]

3. Personal Data We Process

When you use our contact form or write to us, we may process:

• Full name
• Company or organisation
• Email address
• Telephone number, if provided
• Area of interest
• Message content
• Any other information you choose to include in your correspondence

When you visit the website, our hosting provider may automatically process technical information such as your IP address, browser and device information, access times, technical logs and security-related information. Your chosen language is stored in a cookie (see section 12). We do not use analytics or advertising tracking.

4. Purposes and Legal Bases

• Contact enquiries — to handle your enquiry and reply to you. Legal basis: our legitimate interest in responding to business enquiries (Art. 6(1)(f) GDPR) or steps taken at your request prior to entering into a contract (Art. 6(1)(b)).
• Professional relationships — to manage communications with potential clients, investors, owners, operators and other professional contacts. Legal basis: legitimate interests or performance of a contract (Art. 6(1)(f) or (b)).
• Website security — to keep the website functioning, prevent abuse and protect our technical infrastructure. Legal basis: legitimate interests (Art. 6(1)(f)).
• Legal obligations — where processing is required to comply with applicable law. Legal basis: legal obligation (Art. 6(1)(c)).

We do not use your details for marketing without your separate agreement.

5. Recipients and Service Providers

Your personal data is accessible only to authorised Estera representatives and to service providers acting on our instructions, for website hosting, contact form processing, business email delivery, IT security and technical maintenance.

[To be confirmed: names of the hosting, email and contact-form delivery providers, and the data processing agreements in place with them.]

Estera Group does not sell personal data.

6. International Data Transfers

Some of our technical service providers may process data outside the European Economic Area. Where this occurs, we rely on appropriate safeguards such as an adequacy decision of the European Commission (including the EU–US Data Privacy Framework) or the European Commission's Standard Contractual Clauses.

[To be confirmed: which providers process data outside the EEA and the transfer mechanism used for each.]

7. Retention

We keep personal data only for as long as necessary for the purpose for which it was collected. Proposed retention periods, awaiting confirmation:

• One-off or unsuccessful enquiries: generally up to 12 months after the last relevant contact.
• Active business relationships: for the duration of the relationship, followed by the retention periods required by law or justified by our legitimate interests.
• Technical logs: according to our hosting provider's security and operational requirements.
• Cookies: as set out in our Cookie Policy.

8. Security

The website is served exclusively over an encrypted HTTPS connection, and access to enquiries is limited to authorised Estera representatives.

[To be confirmed: further organisational and technical measures applied by Estera and its providers.]

9. Your Rights

Under the GDPR you have the right to:

• access your personal data;
• have inaccurate data rectified;
• have your data erased;
• restrict processing;
• data portability, where applicable;
• object to processing based on legitimate interests;
• withdraw consent at any time, where processing is based on consent;
• not be subject to decisions based solely on automated processing — we do not make such decisions.

To exercise your rights, write to fg@esteragroup.eu or edn@esteragroup.eu. We respond within one month, extendable by two further months where the GDPR allows. We may ask you to verify your identity.

10. Complaints

You may lodge a complaint with the Belgian Data Protection Authority: Gegevensbeschermingsautoriteit / Autorité de protection des données Drukpersstraat 35, 1000 Brussels, Belgium www.gegevensbeschermingsautoriteit.be

11. External Websites

Our website contains ordinary links to LinkedIn and Google Maps. These services are not embedded on our pages and receive no data from this website until you click a link. Once you leave our website, the privacy policy of the respective provider applies.

12. Cookies and Similar Technologies

We use a single strictly necessary cookie to remember your chosen language. Our web fonts are hosted on our own website, so no font requests are sent to third parties. Details are set out in our Cookie Policy.

13. Changes to This Policy

We may update this Privacy Policy when our activities, legal requirements or technical infrastructure change. The date at the top of this page shows the latest revision.