About this privacy notice

For the purposes of data protection law, we are a data controller in respect of your personal data. We are responsible for ensuring that it uses your personal data in compliance with data protection law.

This privacy notice applies if you are a representative of one of our institutional clients. The privacy notice sets out the basis on which any personal data about you that you provide to us, that we create, or that we obtain about you from other sources, will be processed by us. Please take the time to read and understand this privacy notice.

Personal data that we collect about you

We will collect and process the following personal data about you:

• Information that you provide to us or one of our affiliates. This includes information about you that you give us by filling in forms or by communicating with us, whether face-to-face, by phone, e-mail or otherwise. This information may include:

• • basic personal data such as your name, job title and contact information; or
  • any information that you share with us by email or through our website.
• Information we collect or generate about you. This includes but is not limited to:

• • any information regarding the products or services purchased from us;
  • Information on your interactions with us including through our website and at meetings, on calls and CCTV footage; and
  • Your IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
• Information we obtain from other sources.

• • This includes the information we obtain from background and onboarding checks, including where that information is obtained for us by our third party service providers.

Uses of your personal data

Your personal data may be stored and processed by us in the following ways and for the following purposes:

• for ongoing review and improvement of the information provided on our website to ensure it is user friendly and to prevent any potential disruptions or cyber attacks;
• to assess your application for our products or services, where applicable;
• for statistical monitoring and analysis of current attacks on devices and systems and for the on-going adaptation of the solutions provided to secure devices and systems against current attacks;
• to understand feedback on our products and services and to help provide more information on the use of those products and services quickly and easily;
• to communicate with you in order to provide you with services or information about our products and services;
• for the management and administration of our business;
• in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or
• for the administration and maintenance of databases storing personal data.

We are entitled to use your personal data in these ways because:

• we have legal and regulatory obligations that we have to discharge;
• we may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; or
• the use of your personal data as described is necessary for our legitimate business interests (or the legitimate interests of one or more of our affiliates), such as:

• • administering and managing our business;
  • marketing our products and services;
  • ensuring that we comply with laws and regulations that apply to us, including our related internal policies; and
  • protecting our website and systems.

Disclosure of your information to third parties

We may disclose your personal data to our affiliates in the circumstances described below:

• for the purpose of providing or receiving support from our affiliates or their service providers; or
• for the purposes set out in the section headed “Uses of your personal data” above.

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

We may also share your personal data outside of Climate Asset Management and our affiliates:

• 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) for the purposes of providing services to us. These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this privacy notice; and
• to the extent required by law, for example if we are under a duty to make legal or regulatory filings or to disclose your personal data in order to comply with any legal obligation, or if we otherwise need to do so to establish, exercise or defend our legal rights

Transfers of personal data outside the European Economic Area (“EEA”) and UK

The personal data that we collect from you may be transferred to, and stored at, a destination outside the EEA/UK. It may also be processed by staff operating outside of the EEA/UK who work for our affiliates or for one of our suppliers.

Where we transfer your personal data outside the EEA/UK, 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/UK. This can be done in a number of ways, for instance:

• the country to which we send the data is approved by the European Commission/UK Government (as applicable);
• the recipient may have adhered to binding corporate rules (only for intragroup transfers); or
• the recipient has signed a contract based on “model contractual clauses” approved by the UK Government / European Commission (as applicable), obliging them to protect your personal data.

In other circumstances the law may permit us to otherwise transfer your personal data outside the EEA/UK. 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/UK (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 “Contacting us” section below.

Retention of 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; and
• legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.

Your rights

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

• 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 object to, and the right to request that we restrict, our processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to continue processing your personal data and / or to refuse that request; 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 “Contacting us” section below.

Further information about your rights may be obtained by contacting the supervisory data protection authority located in your jurisdiction:

• In the UK, the supervisory data protection authority is the Information Commissioner’s Office (“ICO”)
• A list of National Data Protection Authorities in the EU can be found here.

Contacting us

If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please address questions, comments and requests to Chief Risk & Compliance Officer – Jason Parrish (Jason.Parrish@climateassetmanagement.com).