Skip to main navigation HOME ABOUT US INVESTORS CAREERS CONTACT REACH SOLUTIONS REACH PRINTING SERVICES REACH WORK REACH PLC SHAREHOLDER PRIVACY NOTICE MAY 2018 REACH PLC SHAREHOLDER PRIVACY NOTICE MAY 2018 Shareholder Privacy Notice - Summary This shareholder privacy notice applies to you if you are a natural person and you are either a current or former shareholder of Reach plc (formerly Trinity Mirror plc), or if you currently have, or have previously had, an interest in the shares of Reach plc, whether that interest is legal or beneficial. In summary, we hold your personal data, with the support of our registrar, Equiniti Limited (“Equiniti”), to: • Manage your shareholding interest and allow you to exercise your rights as a shareholder • Maintain the Register of Members and enable trading on the London Stock Exchange • To undertake activities relating to the Register of Members e.g. receive dividends and notice of shareholder meetings • To disseminate information and communicate with you in the way that you tell us you prefer We are committed to keeping your data safe and process your data in accordance with Reach plc’s Privacy Notice. You have rights over the data we hold about you, and for information on your rights, please see Reach plc’s Privacy Notice for information. If you have any questions or concerns, you should contact dataprotection@reachplc.com. Shareholder Privacy Notice Who does this privacy notice apply to, and what is it about? This privacy notice applies to you if you are a natural person and you are either a current or former shareholder of Reach plc, or if you currently have, or have previously had, an interest in the shares of Reach plc, whether that interest is legal or beneficial. Please see Reach plc’s Privacy Notice for more information on uses of your personal data not related to shareholding, and for information on your rights in relation to personal data and what to do if you have any questions or complaints about our use of your personal data. Who is the controller of your personal data? The controller of your personal data that is collected and processed for the purposes explained in this privacy notice is Reach plc or a member of the Reach Group. Regardless of which Reach Group company is the controller, you can always contact us with questions or concerns about your privacy by emailing us at dataprotection@reachplc.com What personal data do we collect about you, and how? We collect certain personal data about you, with the support of our Registrar, Equiniti, including: • your name, address and contact details; • details of your past or present holdings of shares and/or interests in shares in Reach plc, whether you hold or held these as legal owner or have or had a beneficial interest in them; • your bank or building society account details into which dividends and other income or capital returns on your shares have in the past, or should in the future, be paid; • your image/voice, where and if it is captured by visual or audio recording equipment; • information about the transactions and investments you make or have made in the past, including financial data and voting and preference instructions; and • information about other people, such as your spouse, joint holders, appointed proxies, corporate representatives and other connected parties, as necessary for us to administer your shareholding and allow you to exercise your rights. We collect this information in a variety of ways, including: • by you providing it to us by post, phone, or online means; • application and registration forms/identification documentation, including where third parties act on your behalf by providing certain of these details to us, such as stock brokers and other agents; • where you exercise your rights in respect of your shares, including by your attendance at general meetings and voting in person or by your casting proxy votes, whether in hard copy form or by submitting electronic instructions via the CREST system; • from third parties who perform services on our behalf, such as our registrar Equiniti who assists us with maintenance of our share registers and with the conduct of our general meetings; • by capturing your image and/or your voice on visual and/or audio recording equipment, for example on any recordings made of our general meetings if you attend such meetings, and on any recordings made of other presentations to shareholders if you attend such presentations; and • if you are also an employee of a Reach plc group company, by your employing company providing certain of these details to us. What do we do with your personal data, and on what basis? We, with the support of our registrar Equiniti, collect and process personal data about you for the purposes as set out in this Notice: • To give instructions to manage and operate your account to facilitate the administration of your shareholding. This includes retaining records of your instructions and keeping your shareholder records up to date, allowing you to exercise your rights as a shareholder; contacting you with shareholder related information including general meetings and providing you with information about relevant products and services; • Managing our relationship with you: to enable us to otherwise manage our relationship with you, including by meeting with you, communicating with you and answering questions you ask of us, responding to any complaints and data rights that you invoke and keeping your shareholder records up to date; • Legal and regulatory compliance: to comply with laws and regulations to which Reach plc is subject, including those that require us to keep records and file returns about the shareholdings in Reach plc, pay you amounts due on your shares, send you information about Reach plc and comply with disclosure requirements imposed or enforced by governmental authorities and regulatory agencies, including law enforcement agencies and tax authorities; • Contractual compliance: to comply with our contract(s) with you, as set out in the memorandum and articles of association of Reach plc and/or in any share scheme or plan trust deed or rules, including giving you the information and communicating with you in the ways referred to therein, completing transactions that you instruct us to undertake and any pursuant legal obligations, and to provide you with dividends, certificates and notices; • For the purposes of investor analytics administration and share register analysis; • Safety and security: to seek to ensure the safety and security of attendees at our general meetings and at presentations to shareholders, to keep records of those events, and to keep our websites secure; • Dissemination of information: to disseminate information about Reach plc’s business, strategy and financial results, corporate actions and changes to the way in which we manage our Register of Members; and • Other legal purposes: to enable us to enforce or defend our legal rights, including by bringing or defending legal claims that may be made by or against Reach plc in relation to your shareholdings or interests in shares. We process your personal data because we have legal obligations to do so and because it is necessary to perform our contract(s) with you as a shareholder and/or holder of interests in shares in Reach plc. We may process your data to comply with laws and regulations to which Reach plc is subject. You may also have legal obligations to provide us with certain information about you, for example where we make a statutory demand to ascertain the beneficial ownership of shares. Otherwise we process your personal data on the basis of our legitimate interests, which are to achieve those purposes referred to above that do not relate to complying with a legal obligation or performing our contract with you. Where we process your personal data only on the basis of our legitimate interest, you have the right to object to that use. However, we do not have to stop processing personal data where we have compelling grounds to continue, or where we need to process your personal data in order to establish, exercise or defend legal claims. If you have any objections to our use of your data please contact dataprotection@reachplc.com Who will we share your personal data with? We will share your personal data with our registrar Equiniti for the purposes set out in this privacy notice. We may also share your personal data with third party suppliers and service providers to members of the Reach Group, for example professional advisors and third parties who are used by us to perform processing activities, such as our registrar, software service providers and payment service providers. We may share your personal data with members of the Reach Group, for example where they assist us in complying with our legal obligations to you and/or managing our relationship with you. We may share your third parties where we are legally obliged to do so, for example with government bodies and regulatory agencies and with the courts and parties to legal proceedings pursuant to court rules and orders. The third parties who process your personal data on our behalf may do so in countries outside the European Economic Area (EEA). Where that is the case we’ll make sure that suitable safeguards are in place, for example by using approved contractual agreements, unless certain exceptions apply. We can provide more information about this on request. For how long will we process your personal data? We, with the support of our registrar Equiniti, will process your personal data for as long as you hold shares or an interest in shares in Reach plc, and we will also retain your personal data after you cease to hold shares or an interest in shares in Reach plc for a period of 12 years or so as long as necessary to deal with any outstanding matters relating to your holding or interest, including where legal claims have arisen or might arise. We may also retain your personal data where it is comprised in business data which evidences your holding or interest, such as where your name or other information about you appears in business records or reports for as long as we need to keep that evidence for our business purposes. We can keep your data for longer than 12 years if we cannot delete it for legal, regulatory or technical reasons. If we do, we will make sure that your privacy is protected and only use it for those purposes. What rights do you have in relation to your personal data? Please see Reach plc’s Privacy Notice for information. What should you do if you have any questions or complaints? Please see Reach plc’s Privacy Notice for information. Commissioning Terms Privacy Notice Cookie Notice Pension Scheme Disclosure Notices Employee Data Privacy Notice (UK) Employee Data Privacy Notice (ROI) CCTV Policy Corporate Governance Modern Slavery Statement Shareholder Privacy Notice Copyright © 2021 Reach PLC