Email Alerts Privacy Notice

"We", "our" or "us" means Close Brothers Group Plc and its subsidiaries, affiliates and their respective parent and subsidiary companies (“Close Brothers Group”). For the purposes of data protection law, we are a data controller in respect of your personal data. We collect and use your personal data as described below. We are responsible for ensuring that we use your personal data in compliance with data protection law.

If you have any questions about this notice, about how we process personal data or about your rights over your personal data, our Data Protection Officer can be contacted at dpo@closebrothers.com or DPO, Close Brothers, 10 Crown Place, London EC2A 4FT.

This notice only applies to personal data we receive from you or otherwise create in connection with your subscription to our email alert service via the www.closebrothers.com website at https://www.closebrothers.com/media/email-alerts. It is important that you take the time to read this notice so that you understand how we will use your personal data and your rights in relation to your personal data.

Personal data that we collect about you

We will collect and use the following information about you:

Information you give us

• We use the information about you that you provide to us, including the information that you provide when you complete the form at https://www.closebrothers.com/media/email-alerts (such as your name, country of residence, e-mail address, occupation, and your preferences for receiving email alerts from us) and any update to your information that you provide to us when corresponding with us by phone, e-mail or otherwise.

Information we collect or generate about you

• When you submit information to us, we may use this information to help build a better picture of the topics and materials that interest you or may interest you.
• Website Usage Information – Our website uses Google Analytics to automatically gather certain statistical information such as the number and frequency of visitors and their IP addresses. This information is used as aggregated statistical information about users, providing usage by IP address. We do not identify individual users from this type of data and it does not involve the processing of personal data about you. This information helps us to measure how individuals use the website and our services, so that we can continually improve them.
• We sometimes record telephone conversations to resolve complaints, improve our service and for training and quality assurance purposes.
• We generate data for statistical analysis.

How we use your personal data

• Your personal data may be processed by us for the following purposes:
• to provide you with e-mail updates relating to the topics that you request;
• to administer and maintain your subscription account for e-mail alerts; and
• to communicate with you in relation to the administration of your subscription account or to carry out quality control research.

Legal basis for processing your personal data

We process your personal data pursuant to the following legal bases:

• you may have consented for us to use your personal data to send you certain e-mail updates when you signed up for our e-mail alerts;
• the use of your personal data as described is necessary for our legitimate business interests which are:
  • contacting you with email updates that you have requested from us; and
  • keeping a record of what individuals are interested in hearing about from us.

You may cancel your subscription to e-mail alerts at any time by using the unsubcribe link within the email alerts that you receive from us, or by logging into your subscription account at: https://www.closebrothers.com/media/email-alerts using your registered e-mail address.

Sharing your personal data

We may disclose your personal data within the Close Brothers Group and to third party service providers in the circumstances described below:

• to facilitate the delivery and maintenance of our e-mail alert service;
• to conduct and/or improve the business development activities of any member of the Close Brothers Group;
• to ensure the safety and security of our data; and
• as part of our internal research and statistical analysis activity.

We will take steps to ensure that the personal data is accessed only by personnel that have a need to do so for the purposes described in this notice.

We may also share your personal data outside of the Close Brothers Group:

• if we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyer for due diligence purposes;
• if we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third party buyer;
• to third party agents or contractors (for example, the providers of our electronic data storage services or call centres) for the purposes of providing services to us; and
• with your consent, to third party affiliates who may wish to offer you products and services which may be of interest to you.

These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this privacy notice.

We may also share your personal data outside of the Close Brothers Group to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation, and to establish, exercise or defend our legal rights.

Transfer of personal data outside the European Economic Area

The information you provide to us will be transferred to and stored on our secure servers in the European Economic Area (“EEA”). However, from time to time, your personal data may be transferred to, stored in, or accessed from a destination outside the EEA. It may also be processed by staff operating outside of the EEA who work for a company in the Close Brothers Group or for one of our suppliers.

Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA. This can be done in a number of ways, for instance:

• the country that we send the data to might be approved by the European Commission or a relevant data protection authority;
• the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data; or
• where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme.

In other circumstances the law may permit us to otherwise transfer your personal data outside the EEA. In all cases, however, we will ensure that any transfer of your personal data is compliant with data protection law.

You can obtain more details of the protection given to your personal data when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the “Contact us” section below.

How long we keep your personal data

How long we hold your personal data for will vary. The retention period will be determined by various criteria including:

• the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose (for example, to provide e-mail alerts to you for so long as you remain subscribed to them); and
• legal obligations – laws or regulation may set a minimum period for which we have to store your personal data.

Your rights

You have a number of rights in relation to the personal data that we hold about you. These rights include:

• the right to object to our processing of your personal data where we process your personal data pursuant to our legitimate business interests. Please note that there may be circumstances where you object to our processing of your personal data but we are legally entitled to refuse that request;
• the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
• the right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so;
• in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;
• the right to request that we rectify your personal data if it is inaccurate or incomplete;
• the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
• the right to request that we restrict our processing of your personal data in certain circumstances. Please note that there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request;
• the right to object to the processing of your personal data for direct marketing purposes; and
• the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us using the details set out in the “Contact us” section below.

You can find out more information about your rights by contacting the data protection regulator, the Information Commissioner, or by searching their website at https://ico.org.uk/.

Changes to this privacy notice

We keep this privacy notice under regular review. Any changes we make to this notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this privacy notice.

Contact us

Close Brothers Group Plc is a company registered in England and Wales. Our registered address is at 10 Crown Place, London, EC2A 4FT and our company registration number is 00520241.

Please contact us if you have any questions about this notice, our privacy notices or personal data that we may hold about you:

Write to us at: Data Protection, Close Brothers, 10 Crown Place, London EC2A 4FT.

By telephone: 0333 321 6100; or

By email: dpo@closebrothers.com