CREATIVE TECHNOLOGIES LIMITED

PRIVACY AND COOKIES POLICY

As the operators of various products, services and websites (" CT Services"), Creative Technologies Limited (" We", "Us") is committed to protecting and respecting your privacy. This Privacy and Cookies Policy ("Policy") (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to Us will be processed by Us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.

For the purpose of the General Data Protection Regulation (" GDPR", from the GDPR implementation date) or, until GDPR implementation date, the Data Protection Act 1998, (collectively the "Data Protection Laws") the Data Controller is Creative Technologies Limited.

IMPORTANT NOTE TO USERS OF THE WEALTH PLATFORM:

Creative Technologies Ltd is a technology developer and supplier, not a financial adviser. Creative Technologies does not provide any financial advice to you whatsoever. Creative Technologies developed and hosts Wealth Platform for the benefit of your Adviser to facilitate their management of your information and documentation as part of the financial management services the Adviser has agreed to provide to you pursuant to your Adviser Agreement.

By uploading information to Wealth Platform, you are submitting such information to us and our service providers. However, you also understand that the information and/or documentation made available by you through Wealth Platform is also being made available to your Adviser for viewing and consequently your Adviser may make investment decisions based on your information included on Wealth Platform. Your Adviser will also be a Data Controller in respect of personal data uploaded to the Wealth Platform, which will be held and used by the Adviser in accordance with the terms of the Adviser privacy policy. We do not accept any liability or responsibility for Adviser policies and recommend you read such policies prior to uploading any personal data to the Wealth Platform.

YOUR PERSONAL INFORMATION

INFORMATION WE MAY COLLECT FROM YOU

We collect and process some or all of the following types of information from you:

• Information that you provide to us through the CT Services. This includes information provided at the time of registering to use any of the CT Services or requesting further information or services. We may also ask you for information when you report a problem with any of the CT Services.
• Specifically, personal details such as name, email address, or any information input by you when using the CT Services.
• Requesting further information about CT Services. We may also ask you for information when you contact Us by phone or e-mail.
• Information you provide when making any payment through the CT Services.
• If you contact Us, We may keep a record of that correspondence.
• Details of your visit to certain CT Services (e.g. our website), including information viewed or searched for, page response times, lengths of visit, login information, browser type and version, traffic data, location data, weblogs and other communication data, and the resources that you access, so we may compile statistics relating to your use of the CT Services.

For certain CT Services, the provision of your full name, postcode, e-mail address, date of birth, gender, health status, PEP status, salary and other information relating to your assets and liabilities are all required from you in order to register you on a CT Service.

When submitting general enquiries through a CT Service (e.g. Our website), your name, e-mail address and contact number are required from you to enable Us to respond to your enquiry.

We will inform you at the point of collecting information from you, whether you are required to provide any other information to Us.

USES MADE OF YOUR INFORMATION

Lawful basis for processing

We rely on the fulfilment of Our contractual obligations as the lawful basis for processing your personal data. This may be pursuant to any terms and conditions or end user licence agreements you have entered into with Us.

We also rely on "legitimate interests" for processing your personal data. The legitimate interest is processing your personal data as part of the performance of Our contract with your Adviser or is responding and contacting you regarding any enquiries you make in relation to the CT Services We offer

Purposes of processing

We use information held about you in the following ways:

• To provide you with access to and the benefit of the applicable CT Services.
• To respond to any enquiries you submit to Us;
• To ensure that Content on the CT Services is presented in the most effective manner for you and for the device(s) you use to access and view the CT Services;
• To provide you with information and offers that you request from Us or which We feel may interest you.
• To send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you.
• To send you communications such as statements or newsletters you may have requested through the CT Services.
• To operate, protect, improve and optimise the CT Services, Our business, and Our users' experience, such as to perform analytics, conduct research, personalise or otherwise customise your experience, and for advertising and marketing.
• To carry out Our obligations arising from any contracts entered into between you and Us.
• As part of Our efforts to keep the CT Services safe and secure.
• To allow you to participate in interactive features of the CT Services, when you choose to do so.

Marketing

In addition to the above uses We may use your personal data to notify you about additional CT Services which may be of interest to you. For such uses We will only contact you by electronic means (e-mail) if you have provided Us with your email address when We collect your personal data.

If you do not want Us to use your personal data in this way please either (i) tick the relevant box situated on the form or page on which We collect your personal data (for example, a registration form or a website page); (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) inform Us at any time by contacting Us at the contact details set out below.

Third Party Marketing

We will not sell, share or pass your personal data to a third party for marketing purposes unless you have expressly consented to Us doing so.

DISCLOSURE OF YOUR INFORMATION

Your personal data will be disclosed to your Adviser.

We may pass your personal data to our third party service providers, agents, subcontractors and other associated organisations for the purposes of: (i) completing tasks and providing services to you on our behalf (e.g. to host our servers) and (ii) storing, protecting and securing your personal data.

We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).

We may also disclose your personal data to third parties:

• in the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets; or
• if We or substantially all of our assets are acquired by a third party, in which case personal data held by Us about our customers will be one of the transferred assets; or
• if We are under a duty to disclose or share your personal data in order to comply with any legal obligation; or
• to protect Our rights, property, or safety or that of our affiliated entities and our users and any third party We interact with to provide the CT Services.

Other than as set out above, and save insofar as is necessary in order for Us to carry out Our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so.

STORING YOUR PERSONAL DATA

Security

We take appropriate measures to ensure that any personal data is kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. Where We have given you (or where you have chosen) a password which enables you to access certain parts of a CT Service, you are responsible for keeping this password confidential.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do Our best to protect your personal data, We cannot guarantee the security of your data transmitted to a CT Service; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.

Keeping your personal data up to date

If your personal details change you may update them by contacting your Adviser. With certain CT Services, you may update your personal data by contacting Us directly using the contact details below. If you are unsure as to who you should contact, We will endeavour to advise you accordingly. If you have any questions about how We use data collected which relates to you, please contact Us by sending a request by email to the contact details below.

Where you have contacted Us regarding an update to your personal data and We agree that this should be dealt with by Us as opposed to your Adviser, We will endeavour to update your personal data within 14 working days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.

How long we keep your personal data

• We will hold some of your personal data indefinitely for retrospective reporting and metric purposes, in order to comply with the requirements of Our regulators from time to time or pursuant to applicable law.
• We are required to hold your personal data relating to your investments for a minimum period of 5 years and will continue to do so for so long as Our regulators require.
• Any other personal data will be retained for up to 12 months following such time you cease being a user of any CT Services (e.g. you are no longer a registered user).
• If you contact Us as a prospective customer using Our e-mail address or via Our website contact form, requesting general information about our services, We will hold that personal data you choose to provide such as your name, address, e-mail address, for 12 months from our last point of contact.
• If you contact Us as a prospective customer using Our e-mail address or via Our website contact form, requesting quotes and information about Our services in respect of specific projects, We will hold that personal data you choose to provide such as your name, address, e-mail address, for 12 months from Our last point of contact.
• Data such as IP addresses, traffic data, location data, weblogs and other communication data will be retained for 12 months.

Where we store your personal data

All information We hold about you is stored on our secure servers within the EEA.

The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area (" EEA "). By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is held securely and in accordance with this Policy. Countries outside the EEA do not have the same data protection laws as the United Kingdom and EEA and we have therefore ensured that any of our suppliers who may transfer your personal data outside the EEA has put in place appropriate measures to protect your data, either by being a member of the US-EU Privacy Shield, or by entering into a European Commission approved contract (as permitted under Article 46(5) of the General Data Protection Regulation).

If you would like further information please contact Us using the details below. We will not otherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

YOUR RIGHTS

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

• access to your personal data and to certain other supplementary information that this Policy is already designed to address
• require Us to correct any mistakes in your information which We hold
• require the erasure of personal data concerning you in certain situations
• receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
• object at any time to processing of personal data concerning you for direct marketing
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• object in certain other situations to our continued processing of your personal data
• otherwise restrict our processing of your personal data in certain circumstances
• claim compensation for damages caused by our breach of any data protection laws.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

• email, call or write to Us using the “Contact” details below;
• let Us have enough information to identify you,
• let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
• let Us know the information to which your request relates.

HOW TO COMPLAIN

We hope that We can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to modify this Policy at any time. Any changes We may make to Our Policy in the future will be notified and made available to you using the applicable CT Service or via Our website. Your continued use of the CT Services shall be deemed your acceptance of the varied Policy.

INFORMATION ABOUT OUR USE OF COOKIES AND IP ADDRESSES

We may collect information about your mobile phone, computer or other device from which you access any of the CT Services including where available your IP address, operating system and browser type, for systems administration. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to track your usage of our services.

Certain CT Services use cookies to distinguish you from other users of the applicable CT Service. This helps Us to provide you with a good experience when you browse the relevant CT Service and also allows Us to improve CT Service. By using CT Services you agree to our use of cookies as more specifically set out below.

A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

The cookies we use for Our Wealth Platform:

The cookies we use for the Creative Technologies website:

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the applicable CT Service. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit the applicable CT Service.

CONTACT

All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to customerservices@benchmarkcapital.co.uk or write to Us at FAO Support Manager, Creative Technologies, Holmwood House Broadlands Business Campus, Langhurstwood Road, Horsham, West Sussex, RH12 4QP.