GDPR Policy

FREYR Battery is committed to protect and respect your privacy in compliance with EU- General Data Protection Regulation (GDPR) 2016/679, dated April 27th, 2016 where applicable. This Privacy Statement explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and how we keep your data secure.

This Privacy Statement applies to collecting and storing personal data as part of communication and other activities relating to FREYR Battery’s purpose. It applies also to job applicants.

For our employees at FREYR Battery we refer to our internal privacy statement. For data processing related to cookies, we refer to our Cookie Policy, available on our website www.freyrbattery.com.

Who are we?

FREYR Battery aims to provide industrial scale clean battery solutions to reduce global emissions. Listed on the New York Stock Exchange, FREYR Battery’s mission is to produce green battery cells to accelerate the decarbonization of energy and transportation systems globally.

FREYR Battery is responsible for the personal data we collect.

When do we collect personal data about you?

When you interact with us in person, or we interact with you, through correspondence, by phone, by social media, or through our websites, for example in relation to:

• Shareholder meetings;
• Online events;
• Job applications;
• Business relations; and
• Guest registration

Why do we collect and use personal data?

We collect and use personal data mainly to facilitate projects and business processes that support our objective, as well as activity and communication through our website.

We may use your information for the following purposes:

• Allow access to FREYR Battery’s online events such as quarterly earnings press release presentations
• Discuss sales of goods and/or services or other business relations in cases where legitimate and mutual interest is established
• Following up on communication around formal or informal cooperation connected to FREYR Battery’s objective
• Following up on incoming requests (support, emails, chats, or phone calls)
• Perform contractual obligations
• Process a job application

Our legal basis for collecting personal data

Collecting personal data based on consent

We collect personal data based on consent using “Consent Forms” that will store documentation related to the consent given by the individual. Individual consents will always be stored and documented in our systems.

Collecting personal data based on contracts

We use personal information for fulfilling our obligations related to contracts and agreements with FREYR Battery’s customers, partners and suppliers.

Collecting personal data based on legitimate interest

We may use personal data if it is considered to be of legitimate interest, and if the privacy interests of the data subjects do not override this interest.

Normally, to establish the legal basis for data collection, an assessment has been made during which a mutual interest between FREYR Battery and the individual person has been identified. This legal basis is primarily related to FREYR Battery’s objective.

What type of personal data is collected?

We may collect name, phone number and email address, in addition to your company’s name and contact information. We may also collect feedback, comments and questions received from you in service-related communication and activities, such as meetings, phone calls, documents, and emails. From our websites we may collect IP-address and actions taken on the site. We refer to our Cookie Policy available on our website.

If you apply for a job at FREYR Battery, we collect the data you provide during the application process.

How long do we keep your personal data?

We store personal data for as long as we find it necessary to fulfil the purpose for which the personal data was collected, while also considering our need to answer your queries or resolve possible problems, to comply with legal requirements under applicable laws, to attend to any legal claims/complaints, and for safeguarding purposes.

This means that we may retain your personal data for a reasonable period of time after your last interaction with us. When the personal data that we have collected is no longer required, we will delete it in a secure manner.

Your rights to your personal data

You have the following rights with respect to your personal data:

• The right to request a copy of your personal data that FREYR Battery holds about you.
• The right to request that FREYR Battery corrects your personal data if inaccurate or out of date.
• The right to request that your personal data is deleted, unless it is privy to an exception in accordance with GDPR.
• The right to withdraw any consent to personal data processing at any time.
• The right to request that FREYR Battery provides you with your personal data and, if possible, to pass on this information directly (in a portable format) to another data controller when the processing is based on consent or contract.
• The right to request a restriction on further data processing, in case there is a dispute in relation to the accuracy or processing of your personal data.
• The right to object to the processing of personal data, where data processing has been based on legitimate interest.

All queries about privacy rights should be sent to Compliance-Officer@freyrbattery.com.

Do we share your data with anyone?

We do not share, sell, rent, or trade your information with any third parties without your consent, except as stated below.

Third-party Service Providers

We may share your information with suppliers who are providing services to you on our behalf where this information is necessary to be able to perform the service effectively.

Project Partners

We may share your information with partners with whom we collaborate with on projects linked to our objective where the information is necessary for our partner(s) to carry out the project tasks effectively.

Use of suppliers and sub-contractors

(processors and sub-processors)

When using suppliers and sub-contractors who process personal data on our behalf, we are responsible for making sure they commit themselves to adhere to this Privacy Statement and applicable data protection legislation by signing a Data Processing Agreement.

The main data processors used by FREYR Battery are:

• SAP
• Siemens
• AWS

Securing your personal information

We will take reasonable effort to secure your personal information from access by both physical and virtual means. We have internal routines that prevent unauthorized persons from accessing your personal information (confidentiality) and to secure against unauthorized changes to your personal information (integrity).

We ensure that Data Processing Agreements with suppliers and sub- contractors who process personal data on our behalf have adequate data security measures in place.

Changes to this Privacy Statement

FREYR Battery reserves the right to amend this Privacy Statement at any time. The applicable version will always be found on our websites.

If we make changes that significantly alter our privacy practices, we will notify you by email or post a notice on our websites prior to the change taking effect.

Your right to complain with a supervisory authority

If you are unhappy with the way in which your personal data has been processed, you may, in the first instance, contact Compliance-Officer@freyrbattery.com.

If you remain dissatisfied, then you have the right to apply directly to your national supervisory authority for a decision.