Privacy Policy Spayne Lindsay & Co LLP Privacy Policy Spayne Lindsay respects the privacy of every individual whose personal information it handles. This privacy policy explains how we collect, store and use personal information. Where used in this policy, “Spayne Lindsay” means Spayne Lindsay & Co LLP, or any related companies. For applicable legislation, including the EU GDPR, as amended or supplemented, the Spayne Lindsay that you deal with is the controller of your personal information. Personal information of business contacts If you have had contact with Spayne Lindsay, for example through email, business cards or meeting a Spayne Lindsay representative, we may store limited amounts of personal information relating to you, such as your name, job title, employer organisation and contact details. We will collect and store this personal information for the purposes of: Maintaining and record of contacts Providing periodic business updates as described in this policy Inviting you to our events and conferences as well as organising meetings between you and Spayne Lindsay Representatives The personal information we hold about business contacts will only be shared when required for (if you agree): Business purposes as part of a M&A deal process (and only with the owner’s permission) Third party companies who store personal information on behalf of Spayne Lindsay, such as providers of cloud hosting solutions and Client Relationship Management systems Those who we engage for professional compliance, accountancy or legal services Where third parties are involved in processing your data we will have contracts in place with them to ensure that the nature and purpose of the processing is clear; that they are subject to a duty of confidence in processing your data; and that they will only act in accordance with our written instructions. In accordance with the Data Protection Laws, our legal basis for collecting and storing personal information about you is for the performance of any contract we have with you, or when necessary for our legitimate interests in running and promoting our business. Without collecting your personal data, we would be unable to fulfil our legal and regulatory obligations. Different rules apply to data concerning race, ethnic origin, political opinions or beliefs, religious or other similar beliefs, trade union membership, physical or mental health, sexual life and any offences committed and sentences or court proceedings relating to actual or potential offences – these are all called sensitive or special category personal data. Please do not send us sensitive personal data as generally we do not need it. Where special category data is required we will obtain your explicit consent to collect and process this information. Personal information of mandated or potential mandated clients If you are involved in a transaction that Spayne Lindsay enters into, or a potential transaction that Spayne Lindsay considers, we may store personal information relating to you. In accordance with the Data Protection Laws, our legal basis for collecting and storing personal information about you is that such processing is necessary for our legitimate interests in running our business, by considering potential investments, and administering transactions that we enter. If we enter into a transaction that you are involved in, it will also be necessary for us to process your personal information for performing that contract and to comply with our regulatory and legal obligations. Where it is necessary for your personal information to be forwarded to a third party (our Compliance Advisors for example) we will use appropriate security measures to protect your personal information in transit, such as password protection and / or encryption of data etc. To fulfil our obligations in respect of prevention of money-laundering and other financial crime, we may send your details to third party agencies for identity verification purposes. We will explain to you when the provision of information is mandatory, including the possible consequences of not providing information, for example, preventing us from proceeding with a transaction involving you. Spayne Lindsay will only process the personal information you provide to us for the purposes listed above. International transfers or personal information Spayne Lindsay operates across borders around the world. As such, the personal information that we hold may be transferred to, and stored at, a country outside of your country of residence, including countries outside of the EEA, such as the U.S. and India. Where we transfer personal information to other third parties outside of the EEA, we will ensure that those transfers take place in accordance with the Data Protection Laws, including by entering into data transfer agreements with recipients. If you would like more information about how your personal information may be transferred, please contact us using the information below. Cookies Spayne Lindsay do not use cookies directly. We have access to Google Analytics data (gathered using cookies) which shows information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. The Google privacy policy can be seen at this link. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org. To opt out of being tracked by Google Analytics across all websites visit this link. By using our website without adjusting your web browser to block them, you are consenting to these types of cookies being stored on your device. Periodic business updates We may use personal information that we hold to send you periodic updates about Spayne Lindsay’s business, activities and opportunities by email and post. You can opt out of receiving updates at any time by contacting us (reception@spaynelindsay.com), or by clicking the “Unsubscribe” link in any email that you receive. Retention of personal information In principle, your personal information should not be held for longer than is required under the terms of our contract for services with you. However, the period for which Spayne Lindsay will retain personal information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation. For example, if you provide us with your information in connection with the FCA mandatory Client Take On paperwork, we must keep your information for up to five (5) years from the date of last contact with you. Spayne Lindsay also reserve the right to retina information for longer than stated minimum periods due to the possibility that it may be required for legal processes in the future. We will not hold personal information for longer than 10 years before destroying it to the required standard. Your rights Individuals whose personal information we hold may be entitled to access their personal information, or to request that it is erased, that its processing is restricted, or that any inaccurate personal information is rectified. You may also have the right to object to the processing of your personal information, or in some circumstances to obtain a copy of the personal information in machine readable format. Any such request should be submitted in writing for the attention of the Chief Operating Officer (reception@spaynelindsay.com). Individuals also have the right to complain about the use of their personal information to the Supervisory Authority, which in the UK is the Information Commissioner’s Office (www.ico.org.uk). Accuracy and security Spayne Lindsay will take all reasonable steps to keep your personal information accurate and, where necessary, up to date. If you believe that any of the information that Spayne Lindsay holds about you is incorrect please notify us through the following email address: reception@spaynelindsay.com. Spayne Lindsay will take all reasonable steps to protect the confidentiality and security of your personal information but cannot guarantee the security of any data you disclose online. You accept the inherent security risks of providing information online over the Internet and will not hold Spayne Lindsay responsible for any breach of security unless this is due to Spayne Lindsay’s negligence or wilful default. Spayne Lindsay’s websites may contain hypertext links to external websites. Spayne Lindsay is not responsible for and accepts no liability in relation to these websites or their contents. You should read any applicable privacy policy on any such website. Changes to Spayne Lindsay’s Privacy Policy Any changes to this Privacy Policy will be posted here, so please check Spayne Lindsay’s Privacy Policy on a regular basis when you visit our website. How to contact us Please contact us if you have any questions about our privacy policy or information we hold about you: By email at: reception@spaynelindsay.com Or write to us at: Spayne Lindsay & Co LLP, 55 Strand, London, WC2N 5LR Spayne Lindsay & Co. LLP is a limited liability partnership registered in England and Wales under Partnership No. OC307647 and is regulated by the Financial Conduct Authority. Registered office address: Devonshire House, 1 Devonshire Street, London W1W 5DR. Spayne Lindsay & Co Limited is a limited company registered in England and Wales under Company No. 09500191. It is an Appointed Representative of Spayne Lindsay & Co LLP and therefore regulated by the Financial Conduct Authority. Registered office address: Devonshire House, 1 Devonshire Street, London W1W 5DR. 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