BACKGROUND:

East Harbour Associates Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information About Us

East Harbour Associates Limited a limited company registered in the Bailiwick of Guernsey under company number 42436.

Registered office address: 29-31 High Street, St Peter Port, Guernsey.

Our Data Protection Manager can be contacted by email at info@east-harbour.com, by telephone on +44 (0) 1481 712826, or by post at PO Box 106, St Peter Port, Guernsey, GY1 3ER.

2. What Does This Notice Cover?

This Privacy Information explains how we use your personal data, how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

3. What is Personal Data?

Personal data is defined by The Data Protection (Bailiwick of Guernsey) Law 2017 (“the Guernsey Law”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

4. What Are My Rights?

Under the Guernsey Law, you have the following rights, which we will always work to uphold:

a) The right to be informed about collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.

b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.

d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal data.

f) The right to object to us using your personal data for a particular purpose or purposes.

g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

Further information about your rights can be obtained from the Guernsey Data Protection Commissioner. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Guernsey Data Protection Commissioner who can be contacted on +44 (0) 1481 742074 and its website, which includes details of how to make a complaint, at www.dataci.org.

5. What Personal Data Do You Collect?

We may collect some or all of the following personal data (this may vary according to your relationship with us):

• Personal details (Name, Address, Date of Birth, Nationality, Gender, Email Address, Telephone Number);

• Professional details (Job title, Profession, Business Name);

• Information that we learn about you through our relationship;

• information that we gather from publicly available sources, such as the press, online search engines;

• Financial information, such as payment related information;

Information regarding meetings attended;

• Any other information you provide to us.

6. How Do You Use My Personal Data?

Under the Guernsey Law, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:

• Providing and managing your account.

• Supplying our products & services to you. Your personal details are required in order for us to enter into a contract with you.

• Personalising and tailoring our products & services for you.

• Communicating with you. This may include responding to emails or calls from you.

• Supplying you with marketing information by email and post that you have opted-in to (you may unsubscribe or opt-out at any time by sending an email to info@east-harbour.com).

7. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.

If the data is no longer required for the fulfilment of these obligations, it will be deleted at regular intervals, unless it is still required for temporary further processing.

8. How and Where Do You Store or Transfer My Personal Data?

We use specific contracts with external trusted parties, (e.g. cloud providers) that are approved by the European Commission for the transfer of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the Guernsey Law.

You can contact us using the details below in Part 11 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.

9. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, unless we may be legally required to do so, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

10. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you we will supply a Subject Access Request Form for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

11. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: info@east-harbour.com.

Telephone number: +44 1481 712826.

Postal Address: PO Box 106, St Peter Port, Guernsey, GY1 3ER.

12. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available www.east-harbour.com/data_privacy_policy.

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