Special Project Partners Ltd

Privacy and Data Protection Policy

20 February 2019

Preliminaries

This notice explains what information we collect, when we collect it and how we use it. During the course of our activities, we will process personal data (which may be held on paper, electronically, or otherwise) about you and your company (if applicable) and we recognise the need to treat it in an appropriate and lawful manner. The purpose of this notice is to make you aware of how we will handle your information.

Who are we?

Special Project Partners Ltd take the issue of security and data protection very seriously and strictly adhere to guidelines published in the General Data Protection Regulation (EU) 2016/679, applicable from the 25th May 2018, together with any domestic laws subsequently enacted.

Any questions relating to this notice and our privacy practices should be sent to privacy@spp.global.

How we collect information from you and what information we collect

Like many site operators, we collect information that your browser sends whenever you visit our website (Log Data).

This Log Data may include information such as your computer’s Internet Protocol (IP) address, browser type, browser version, the pages of http://www.spp.global that you visit, the time and date of your visit, the time spent on those pages and other statistics.

In addition, we use third party services such as Google Analytics that collect, monitor and analyse the following information:

• Time of visit, pages visited, and time spent on each page of the webpages
• Referring site details (such as the URL a user came through to arrive at this site)
• Type of web browser
• Type of operating system (OS)
• Flash version, JavaScript support, screen resolution, and screen colour processing ability
• Document downloads
• Clicks on links leading to external websites
• Errors when users fill out forms
• Clicks on videos
• Scroll depth
• Interactions with site-specific widgets.
• Network location and IP address.

Cookies

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive.

Like many sites, we use cookies to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our site.

Personal data

In the course of business we may also collect the following information about and from you:

• Names, company name(s), postal addresses, e-mail addresses, telephone numbers.
• Anonymised information regarding your stakeholders
• Bank account details

Why we need this information about you and how it will be used

We need your information and will use your information:

• to undertake and perform our obligations and duties to you in accordance with the terms of our contract with you;
• to enable us to supply you with the services and information which you have requested;
• to help you to manage your services;
• to analyse the information we collect so that we can administer, support and improve and develop our business and the services we offer;
• to contact you in order to send you details of any changes to our or suppliers which may affect you; and
• for all other purposes consistent with the proper performance of our operations and business.

Sharing of Your Information

The information you provide to us will be treated by us as confidential. We may disclose your information to other third parties who act for us for the purposes set out in this notice or for purposes approved by you, including the following:

• If we enter into a joint venture with a business entity, your information may be disclosed to our new business partners;
• To carry out due diligence on you as a prospective client.
• Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.

Transfers outside the UK and Europe

Your information will only be stored within the UK and EEA. However, if information is transferred outside the UK or EEA, we ensure that there are adequate safeguards in place to protect your information in accordance with this notice.

Security

When you give us information, we take steps to make sure that it is kept secure and safe. Data is held on encrypted and password-protected servers to which only agents of SPP have access.

The security of your information is important to us, but remember that no method of transmission over the internet, or method of electronic storage, can be 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

How long we will keep your information

We review our data retention periods regularly and will only hold your data for as long as is necessary for the relevant activity, or as required by law, or as set out in any relevant contract we have with you.

Changes to this Policy

This Policy is effective as of today’s date. Any changes will take effect immediately after being posted on this page.

We reserve the right to update or change this policy at any time and you should check it periodically. Your continued use of our services after we post any modifications to this policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified policy.

If we make any material changes to this policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

Your Rights

You have the right at any time to:

• ask for a copy of the information about you held by us in our records;
• require us to correct any inaccuracies in your information;
• make a request to us to delete what personal data of yours we hold; and
• object to receiving any marketing communications from us.

If you would like to exercise any of your rights above please contact us at privacy@spp.global.

Should you wish to complain about the use of your information, we would ask that you contact us to resolve this matter in the first instance. You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information. The Information Commissioner’s contact details are noted below:

England:

Information Commissioner’s Office

Wycliffe House, Water Lane

Wilmslow, Cheshire, SK9 5AF

Telephone: 0303 123 1113

Email: casework@ico.org.uk

Scotland:

The Information Commissioner’s Office – Scotland

45 Melville Street, Edinburgh, EH3 7HL

Telephone: 0131 244 9001

Email: Scotland@ico.org.uk

Wales:

Information Commissioner’s Office

2nd floor, Churchill House

Churchill way, Cardiff, CF10 2HH

Telephone: 029 2067 8400

Email: wales@ico.org.uk

Northern Ireland:

Information Commissioner’s Office

3rd Floor, 14 Cromac Place

Belfast, BT7 2JB

Telephone: 028 9027 8757

Email: ni@ico.org.uk

The accuracy of your information is important to us – please help us keep our records updated by informing us of any changes to your email address and other contact details.

On behalf of the SPP board of directors