Auditrek Privacy Statement

Privacy Statement – www.auditrek.co.uk

Auditrek is owned by Fintrek Limited (a private limited company registered in England and Wales with number 12798684 with a registered address of 53 Rawnsley Avenue, London CR4 4BX). This Privacy Statement describes how and why Fintrek Limited (“we” or “us”) collects and uses personal data (i.e. data relating to an identified or identifiable individual) in the course of its business. It applies to personal data provided directly to us by the individuals concerned and to personal data provided to us by companies and other organisations. We are committed to the protection of personal data and to fair and transparent processing. If you have any questions about this Privacy Statement, you can contact our Data Protection Officer via email at [email protected]. To find out more about how and why we process personal data, please refer to the relevant section of this Privacy Statement.

Security of personal data

We have policies, procedures and training in place in respect of data protection, confidentiality and information security. We regularly review such measures with the objective of ensuring their continuing effectiveness. The Privacy Statement was last updated on 01 January 2021 and is reviewed at least annually.

International transfers of personal data In the course of running our business and providing services to clients we may transfer personal data to third parties located in other countries, including countries outside the EEA. Where we transfer personal data to a country not determined by the European Commission to provide an adequate level of protection for personal data, we will only do so under a form of agreement approved by the European Commission, such as the Standard Contractual Clauses.

Provision of personal data to third parties

We will only share personal data with third parties where we are legally permitted to do so. We do not provide information to third parties for their own marketing purposes and we do not undertake mailings for third parties. Where we transfer personal data to third parties, we will put in place appropriate contractual arrangements and seek to ensure that there are appropriate technical and organisational measures in place to protect personal data. We may provide personal data to:

• Business partners– we may share personal data with our business partners as required for the provision of services to our clients and/or for administrative purposes.

• Third parties involved in the performance of services – we may also share personal data to third party organisations who assist us in providing services to clients or are otherwise involved in the services we provide to clients.

• Third parties who provide IT services, data processing or functionality – like many professional service providers, we use third party providers to support our business and the provision of services to our clients, such as cloud based software providers, web hosting/management providers, data analysis providers, and data back-up and security/storage providers. We may transfer personal data to such third parties.

• Auditors and advisers – we may transfer personal data to our auditors and advisers as required by law or as reasonably required in the management of our business.

• Third parties where required by applicable law and regulation – we may be requested or compelled to disclose personal data to third parties such as regulators and law enforcement agencies. We will only provide personal data to such parties where there is a legal requirement or permission to do so.

Your Rights

You have rights in relation to any of your personal data held by us as a data controller. Should you wish to exercise your rights right, please contact our Data Protection Officer via email at [email protected]. Please mark the subject with ‘DPO Enquiry’. We will endeavour to respond to any request promptly and within any legally required time limit. You also have a right to update your personal data that we hold. Where we process your personal data based on your consent, you have a right to withdraw consent at any time. Should you wish to do so, please contact our Data Protection Officer via the email stated above.

Finally, in addition to the rights above, you may also have other rights in relation to personal data, including a right to erasure/deletion, the right to data portability and the right to restrict and/or object to our processing of personal data. Such rights may only be available to you from 25 May 2018, when the General Data Protection Regulation comes into effect.

Complaints

Should you wish to complain about our use of your personal data, please contact our Data Protection Officer via email at [email protected]. Please mark the email subject as DPO – Complaints’ We will investigate all complaints received and will endeavour to respond to complaints promptly.

You may also complain about our use of personal data to the Information Commissioner’s Office. For further information on your rights and the complaints process, please visit the Information Commissioner’s Office website: https://ico.org.uk/for-the-public/raising-concerns/.

Data Retention

Generally we avoid requesting any personal data as part of our services or operations, however if we request such data then we will only keep personal data for as long as necessary for the purposes for which it was collected, or as required by applicable law or regulation. Unless there are any overriding legal, regulatory or contractual requirements, we will retain records of services provided (which may include personal data) in accordance with our document retention policy.

Clients (and individuals connected with our clients)

• Provision of professional services – We undertake a wide range of services and we may have to process personal data in order to perform such services and/or provide advice and deliverables to our clients.

• Managing, administering and developing our business – We process personal data in order to manage our relationship with clients, develop our business and services, maintain and develop our IT systems, manage and host events, and to administer and manage our website, systems and applications.

• Quality and risk management and security – we use various measures to protect personal data and other client information, which include monitoring the services provided to clients to detect, investigate and resolve security threats. Such monitoring may involve processing personal data, for example the automatic scanning of email correspondence for threats. Our client take-on procedures involve processing personal data that may be obtained from publicly available sources (such as sanctions lists, criminal convictions databases, and general internet searches) to identify any risks relating to individuals and organisations that may prevent us from working for a particular client or on a particular matter.

• Providing information about our services to our clients – unless the relevant individual has opted-out, we may use client business contact details to provide information about our services and activities and events that may be of interest.

• Compliance with legal and regulatory obligations – as a regulated firm, we are subject to various legal, regulatory and professional obligations that may require us to process and/or retain personal data held on our client files.

Personal clients

We aim to collect personal data only to the extent necessary for us to provide our services to our clients and for other agreed purposes. Where personal data is required for us to perform services for our clients, we request that our clients provide all necessary information to other relevant individuals (known as “data subjects”) about our use of personal data. Our clients may therefore refer other data subjects to this Privacy Notice. We provide a range of services to personal clients. We may therefore process a range of personal data, as is appropriate for the performance of services, including contact details, business activities, family information and financial information such as details of income, taxation, financial interests and investments. Our services do not require us to obtain or process special categories of personal data such as race or ethnic origin, physical and mental health, sexual life and orientation, criminal records, and political, religious and philosophical beliefs. If we require such data we will only process it with the individual’s consent or as otherwise required by law or regulation. We generally collect personal data directly from our personal clients or from third parties acting on their instructions. Such personal data may be used for the following purposes:

• Provision of professional services – We undertake a wide range of services and may have to process personal data in order to perform such services and/or provide advice and deliverables to our clients.

• Compliance with legal and regulatory obligations –Various legal, regulatory and professional obligations may require us to process and/or retain personal data held on our client files.

Individuals whose personal data we process where providing services to our clients

We aim to collect personal data only to the extent necessary for us to provide our services to our clients and for other agreed purposes. Where personal data is required for us to perform services for our clients, we request that our clients provide all necessary information to relevant individuals (known as “data subjects”) about our use of personal data. Our clients may therefore refer data subjects to this Privacy Notice. We provide a range of services to clients and in doing so may process personal data that relates to third parties with a business connection to our clients, such as other advisers, suppliers, transaction counterparties etc. The personal data we process may include contact details, details of business activities, information relating to management and employees, payroll details, and financial information such as details of income, taxation, financial interests and investments. We generally collect personal data directly from our clients or from third parties acting on their instructions. We may also collect personal data directly from third parties such as transaction counterparties. Such personal data may be used for the following purposes:

• Provision of professional services – We undertake a wide range of services may have to process personal data in order to perform such services and/or provide advice and deliverables to our clients.

• Compliance with legal and regulatory obligations –Various legal, regulatory and professional obligations may require us to process and/or retain personal data held on our client files.

Third Parties (and individuals connected with our suppliers)

We aim to collect personal data about our third parties suppliers (which for the purposes of this notice includes subcontractors that we use to provide services to clients) only to the extent necessary for us to receive services and goods from our suppliers, manage our relationship with our suppliers and facilitate the provision of services to our clients. Our suppliers may refer data subjects to this Privacy Notice. We generally collect personal data directly from our suppliers but sometimes also from third parties such as credit rating agencies. Such personal data may be used for the following purposes:

• Provision of professional services – We undertake a wide range of services and may have to process personal data received from suppliers in order to perform such services and/or provide advice and deliverables to our clients.

• Quality and risk management and security – we use various measures to protect personal data and other client information, which include monitoring the services provided to clients to detect, investigate and resolve security threats. Such monitoring may involve processing personal data, for example the automatic scanning of email correspondence for threats. Our supplier take-on procedures involve processing personal data that may be obtained from publicly available sources (such as sanctions lists, criminal convictions databases, and general internet searches) to identify any risks relating to individuals and organisations that may prevent us from working with a particular supplier.

• Providing information about our services to our clients – unless the relevant individual has opted-out, we may use supplier (typically subcontractor) business contact details to provide information about our services.

• Compliance with legal and regulatory obligations –Various legal, regulatory and professional obligations may require us to process and/or retain personal data obtained from suppliers.

Contacts

We use a customer relationship management system to collect and process personal data about business contacts such as existing clients, prospective clients and their representatives. Such personal data will typically include name, identity of employer, job title, email address, office address, telephone number and other contact details. We collect such personal data directly from the contact to whom the personal data relates. We may use such personal data and make it accessible to our people for the following purposes:

• Managing, administering and developing our business

• Providing information to clients and prospective client about our services

• Identifying our clients or prospective clients’ business needs

• Analyzing interactions between our people and our contacts to provide information to our management on relationships and trends, including the use of an automated analytical tool to evaluate the frequency and timing of interactions with contacts.

We do not sell or otherwise release any personal data collected from contacts to third parties unless we have first obtained consent from the relevant contacts to do so.

Website visitors What personal data do you collect when I visit the www.fintrek.co.uk website?

We do not require registration in order for you to access www.fintrek.co.uk, but if you participate in any of the activities or services offered by the website, we will collect the personal data that we need in order to provide you with those services, such as your name, job title, email address, employer’s name, and telephone number. We may also collect technical information such as your IP (Internet Protocol) address, details of the pages you visit our webpages and which browser you used to view or website.

This website collects standard internet log and technical data to measure and improve the effectiveness of this website, to help diagnose problems with our server, to administer this website, to see where website traffic is coming from and to identify our users. We may also collect other information via www.fintrek.co.uk, such as website usage activity and preferences, also known as demographic or profile data. In this connection we may use “cookies” to collect this information. For more information see our Cookie Policy. We do not seek to collect any sensitive personal information from you on www.fintrek.co.uk, such as information in respect of your race or ethnic origin, political opinions, religious or other similar beliefs, physical or mental health, sexual orientation or criminal record. Where you provide sensitive personal information to us voluntarily, your doing so will constitute your explicit consent to us using that information in connection with the purpose for which it has been provided.

What do you use personal data collected through the www.fintrek.co.uk website for?

When we collect personal information from you in the following circumstances, we will use it for the stated purpose or any purpose that is obvious e.g. when you:

• subscribe to any of our insights, e.g. newsletters, events;

• subscribe to any of our blogs;

• register to attend an event;

• enter a discussion forum;

• contact us to request further information; and

• request to download a document, e.g. report, newsletter.

We aim to collect the minimum amount of information necessary to enable us to deal with your request. We will indicate where the provision of information is voluntary or compulsory. We would normally only request additional information to enable us to provide the most appropriate response to your request. Unless you ask us not to, we may also use your data to contact you with information about our business, services and events, and other information which may be of interest to you.