4th Floor, Salisbury House, London Wall, London EC2M5QQ
Tel: +44 (0) 20 7070 4600

Fax: +44 (0) 20 7070 4649

PRIVACY NOTICE

1PURPOSE OF THIS NOTICEThis privacy notice (“Notice”) explains how your personal data is collected, used anddisclosed by Tokai Tokyo Securities Europe Limited (the “Company”, “we” , “our” or“us”) with respect to our business services with you (the “Services”). You are under nostatutory or contractual obligation to provide your personal data to the Company.
However, if you do not provide the information, the Company may not be able to provide
the Services or enter into a contract.
2DEFINITIONS“Data Protection Legislation” means all the applicable data privacy laws and guidance,including the EU General Data Protection Regulation (2016/679) (“GDPR”) and, in theUK, the Data Protection Act 2018.
“personal data” means any information about a living individual from which that person
can be identified. It does not include data where the identity has been removed (anonymousdata).
3

PERSONAL DATA WE COLLECT

We collect certain personal data in the course of providing and receiving the Services. We
may collect the personal data directly from you through communications, applications orother forms, whether we receive these in writing or electronically.
This data can include: Identity data we use to identify or authenticate individuals or to meet tax, anti-money
laundering (“AML”) and other “Know Your Client” (“KYC”) legal and regulatory
obligations, such as details of name, address (private and professional), employer,age/date of birth, nationality, sex, civil status, photograph, place of birth(City/Country), Individual Tax ID and information to assist us to determine whetherthe individual is a Politically Exposed Person (“PEP”), which may include information
about criminal convictions if we are authorised to use this information under Data
Protection Legislation. This may also extend to historic information about principals
including past employment and qualifications; Employment data includes industry, role, business activities, and names of current orformer employers; Contact data we use to communicate with clients, suppliers and agents such as detailsof name, position, current and former addresses (private and professional), telephone
number (private and professional), email address;

Authorised and regulated by the Financial Conduct Authority
A wholly owned subsidiary of TOKAI TOKYO FINANCIAL HOLDINGS, INC
Registered in England number: 05922339

 Financial data includes bank account, transaction and payment card details made andreceived and goods and services provided or purchased; Transaction Data includes details about payments to and from you and other detailsof products and services you have purchased from us; Technical data that is captured in our web logs such as your device information, unique
identification numbers (such as an IP address or device ID), browser information (e.g.
URL, browser type and version, pages visited, date/time of access); and Communications data including communications by email, telephone or post in thecourse of communicating with clients, suppliers and agents and providing services toclients, including recordings of telephone calls.
4

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through: Direct interactions: you may give us your Identity, Contact and Financial data byfilling in forms or by corresponding with us by post, phone, email or otherwise. This
includes personal data you provide when you:
apply for our services;
request marketing to be sent to you; orgive us some feedback
 Automated technologies or interactions: as you interact with our website, we may
automatically collect Technical data about your equipment, browsing actions andpatterns. We collect this personal data by using server logs and other similar
technologies.
 Third parties or publicly available sources: we may receive personal data about you
from various third parties and public sources as set out below:
o Your employer, where the same is one of our customers or vendorso Technical data from analytics providers such as Google who may be based outside
the EUo Identity and Contact data from publicly availably sources such as Companies House
based inside the EU.
5

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will
use your personal data in the following circumstances: Where we need to perform the contract we are about to enter into or have entered intowith you;
 Where it is necessary for our legitimate interests (or those of a third party) and yourinterests and fundamental rights do not override those interests. A legitimate interest
means the interest of our business in conducting and managing our business. We makesure we consider and balance any potential impact on you (both positive and negative)and your rights before we process your personal data for our legitimate interests. We
do not use your personal data for activities where our interests are overridden by theimpact on you (unless we have your consent or are otherwise required or permitted toby law); or
Authorised and regulated by the Financial Conduct Authority
A wholly owned subsidiary of TOKAI TOKYO FINANCIAL HOLDINGS, INC
Registered in England number: 05922339

 Where we need to comply with a legal or regulatory obligation that we are subject to.
Generally we do not rely on consent as a legal basis for processing your personal data otherthan in relation to sending direct marketing communications to you via email where wemay seek your consent; alternatively we may provide marketing information on the basisof legitimate interest. Irrespective of the basis on which we process your data to provide
marketing communications, you have the right to withdraw consent to marketing at any
time by contacting the Data Protection Officer, in addition to which our emails contain an
unsubscribe option.
Purpose for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use yourpersonal data, and which of the legal bases we rely on to do so. We have also identified
what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground dependingon the specific purpose for which we are using your data.
Please contact us if you need details about the specific legal ground we are relying on toprocess your personal data where more than one ground has been set out in the table below.
Purpose/Activity

Type of data

Lawful basis for processing including basisof legitimate interest

Anti-money launderinga) Identity(AML)/Know your clientb) Employment(KYC)c) Contact

Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests toprevent fraud, sanctions violations, andmoney laundering

Client account openinga) Identity

Performance of a contract with youb) Employmentc) Contact

Necessary to comply with a legal obligationd) Financial
Necessary for our legitimate interests inorder to facilitate the growth of our businessand initiate or expand upon our trading
relationship with you
To provide services to youa) Identity

including:b) Employment(a) Manage payments, feesc) Contact

Necessary for our legitimate interests (toand chargesd) Financial

recover debts due to us)(b) Collect and recovere) Transaction

money owed to usf) Communications

To receive goods or servicesa) Identity

from youb) Employmentc) Contact

Performance of a contract with you

Performance of a contract with you
Necessary for our legitimate interests

Authorised and regulated by the Financial Conduct Authority
A wholly owned subsidiary of TOKAI TOKYO FINANCIAL HOLDINGS, INC
Registered in England number: 05922339

d) Financial
To manage our relationshipa) Identitywith you which will include:b) Employmenta) Notifying you aboutc) Contactchanges to our terms or thisd) Communications

Performance of a contract with you
Necessary to comply with a legal obligation

NoticeNecessary for our legitimate interests (tob) Notifying you of changes

keep our records updated and enhance ourto relevant policies andrelationship with you) provided theseprocedures which impact

interests are not outweighed by yourupon the services we provide

fundamental rights and freedoms

or receive from you.
c) Prospectingd) Provision of researchCompliance and regulatorya) Identity

requirementsb) Employment

Necessary to comply with a legal obligationc) Contactd) FinancialHealth and safety assessmentsa) Identity

Necessary to comply with a legal obligationb) Employmentc) Contact

Necessary for our legitimate interests for thepurpose of providing a safe and secureenvironment on our premises

Risk Management to managea) Identity

Necessary to comply with a legal obligation

our staffing, concentration,b) Employment

liquidity, credit, market,c) Contact

Necessary for our legitimate interests for theoperational, business andd) Financial

purpose of managing the risks to which ourreputation riske) Transaction

business is exposedf) Communications
To administer and protect oura) Identity

Necessary for our legitimate interests (forbusiness and our websiteb) Contact

running our business, provision of(including troubleshooting,c) Technicaladministration and IT services, network

data analysis, testing, systemsecurity, to prevent fraud and in the context

maintenance, support,of a business reorganisation or groupreporting and hosting of data)

restructuring exercise)
Necessary to comply with a legal obligation

6DATA RETENTION

We will retain your personal data covered by this Notice for as long as required to performthe purposes for which the data was collected, depending on the legal basis on which thatdata was obtained and/or whether additional legal/regulatory obligations mandate that weretain the personal data. In general terms, this will mean that the personal data will be kept
for the duration of our relationship with you and:
 the period required by tax, company and financial services laws and regulations; and as long as it is necessary for you to be able to bring a claim against us and for us to beable to defend ourselves against any legal claims. This will generally be the length ofAuthorised and regulated by the Financial Conduct Authority
A wholly owned subsidiary of TOKAI TOKYO FINANCIAL HOLDINGS, INC
Registered in England number: 05922339

the relationship plus the length of any applicable statutory limitation period underapplicable law.
In certain circumstances, personal data may need to be retained for a longer period of time,for example, where we are in ongoing correspondence or there is a continuing claim orinvestigation.
7

YOUR LEGAL RIGTHTS

You will have certain rights in relation to your personal data. Some of these rights will
only apply in certain circumstances. If you would like to exercise, or discuss, any of theserights, you should submit their request in writing or email to the Data Protection Officerand provide sufficient information to allow us to understand the scope of the request.
 Consent: if our processing is based on consent, you can withdraw their consent at anytime by contacting the Data Protection Officer.
 Access: you are entitled to ask us if we are processing your personal data and, if weare, you can request access to your personal data. This enables you to receive a copyof the personal data we hold about you and certain other information about it.
 Correction: you are entitled to request that any incomplete or inaccurate personal
data we hold about you is corrected.
 Erasure: you are entitled to ask us to delete or remove your personal data in certain
circumstances. There are also certain exceptions where we may refuse a request forerasure, for example, where the personal data is required for compliance with law orin connection with claims.
 Restriction: you are entitled to ask us to suspend the processing of their personaldata, for example if you want us to establish its accuracy or the reason for processingit.
 Transfer: you are entitled to request the transfer of your personal data to another third
party in limited circumstances.
 Objection: where we are processing your personal data based on legitimate interests(or those of a third party) you may challenge this. However we may be entitled tocontinue processing the personal data based on our compelling legitimate interests or
where this is relevant to legal claims. You also have the right to object where we areprocessing personal data for direct marketing purposes.
 Automated decisions: you are entitled to contest any automated decision made about
you where this has a legal or similarly significant effect and ask for it to bereconsidered.
 Supervisory Authority: you also have a right to lodge a complaint with a supervisory
authority, in particular in the Member State in the European Union where you arehabitually resident, where you work or where an alleged infringement of Data
Protection Legislation has taken place.
8DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes
set out in the table in paragraph 5 above.

Authorised and regulated by the Financial Conduct Authority
A wholly owned subsidiary of TOKAI TOKYO FINANCIAL HOLDINGS, INC
Registered in England number: 05922339

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Tokai Tokyo Financial Group companies in order to operate corporate, back office,internal administrative functions and in order to meet the purposes for which wecollect and use your personal data;
Credit reference and other third party agencies and suppliers in order to carry out
AML, KYC and PEP checks and comply with legal obligations;Third parties who work on our behalf or for the clients to service or maintain client
accounts, such as administrators and managers including those external to us;
Third parties who are our IT service providers and provide IT support services andperform functions on our behalf and store all email and contact details data for ourclients;
Third parties who provide technical services to process transactions, such as suppliersof trading applications and other IT systems, and print services, which we use toprocess that personal data;
Third parties who manage our physical premises;
Third parties who service or maintain our business contact database and those who
support our website;
Third parties providing services to us such as our professional advisers (e.g. auditorsand lawyers);
A party representing a client, supplier or agent (for example, in response to legalprocess);
Competent authorities such as tax authorities, courts, regulators and other government
agencies, security or police authorities where required or requested by law or where
we consider it necessary (to the extent permitted by law); andThird parties to whom we may choose to sell, transfer, or merge parts of our businessor our assets. Alternatively, we may seek to acquire other businesses or merge withthem. If a change happens to our business, then the new owners may use your personal
data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it inaccordance with the law. We do not allow our third-party service providers to use yourpersonal data for their own purposes and only permit them to process your personal data
for specified purposes and in accordance with our instructions.
9INTERNATIONAL TRANSFER OF DATA

We may share your personal data with other members of Tokai Tokyo Financial Groupcompanies. This may involve transferring your data outside the European Economic Area(the “EEA”).
Whenever we transfer your personal data out of the EEA, we ensure a similar degree ofprotection is afforded to it by ensuring at least one of the following safeguards isimplemented:
 We will only transfer your personal data to countries that have been deemed toprovide an adequate level of protection for personal data by the EuropeanCommission.

Authorised and regulated by the Financial Conduct Authority
A wholly owned subsidiary of TOKAI TOKYO FINANCIAL HOLDINGS, INC
Registered in England number: 05922339



Where we use certain service providers, we may use specific contracts approvedby the European Commission which give personal data the same protection it hasin Europe.
Where we use providers based in the US, we may transfer data to them if they arepart of the Privacy Shield which requires them to provide similar protection topersonal data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us
when transferring your personal data out of the EEA.
10COMPLAINT

You have the right to make a complaint at any time to the Information Commissioner’sOffice (“ICO”), the UK supervisory authority for data protection issues(https://ico.org.uk/concerns/) or the supervisory authority in your home territory. We
would, however, appreciate the chance to deal with your concerns before you approach
the ICO or a relevant supervisory authority, so please contact us in the first instance.
11CHANGES TO THIS NOTICE

We may amend or update this Notice from time to time in whole or part, at our sole
discretion. Any changes to this Notice will be effective immediately and this amended
document will also be updated on our website at:
http://www.tokaitokyo-fh.jp/corporate/group/europe/
12

CONTACT INFORMATIONYour privacy is important to us. If you have any questions, concerns or complaints
regarding this Notice or practices, or if you wish to access, verify, correct or delete any
personal data we have collected, please contact the Data Protection Officer at:
Full name of legal entity: Tokai Tokyo Securities Europe Limited
Postal address: 4th Floor, Salisbury House, London Wall, London, EC2M 5QQ
Telephone number: +44 (0)20 7070 4600
Email: info@tokaitokyo.co.uk
You can also complain to the Information Commissioners Office (“ICO”) if you areunhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
CheshireSK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
Authorised and regulated by the Financial Conduct Authority
A wholly owned subsidiary of TOKAI TOKYO FINANCIAL HOLDINGS, INC
Registered in England number: 05922339