Data Protection Notice

Controller

AVERICO Holdings LLC is the data controller for personal data processed through our websites and services. For engagements with specific AVERICO entities:

• United States: AVERICO Holdings LLC (Delaware)
• Liberia: AVERICO Liberia
• China: AVERICO China (WFOE)

Legal Bases for Processing

We process personal data on the following legal bases:

• Contractual Necessity: Processing required to perform services under an engagement agreement
• Legitimate Interest: Business development, service improvement, and security
• Legal Obligation: Compliance with regulatory requirements, government contracting obligations, and tax law
• Consent: Where required by applicable law, particularly for marketing communications

International Transfers

Personal data may be transferred between AVERICO entities in the United States, Liberia, and China. We implement appropriate safeguards including:

• Intercompany data transfer agreements
• Technical and organizational security measures
• Data minimization principles

Security Measures

We implement appropriate technical and organizational measures to protect personal data, including:

• Encryption in transit and at rest
• Access controls and authentication
• Regular security assessments
• Incident response procedures

Data Subject Rights

Depending on your jurisdiction, you may exercise the following rights:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate data
• Erasure: Request deletion where legally permitted
• Restriction: Restrict processing in certain circumstances
• Portability: Receive your data in a structured format
• Objection: Object to processing based on legitimate interest

Data Protection Contact

dpo@averico.com

Data Protection Officer, AVERICO Holdings LLC

Supervisory Authority

You have the right to lodge a complaint with a supervisory authority in your jurisdiction.