Mashariki Way GDPR Privacy Notice

Mashariki Way respects your privacy and is committed to protecting your personal information. This privacy notice will inform you as to how we look after your personal information and tells you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click the arrows to reveal further detail.

1. IMPORTANT INFORMATION

Mashariki Way respects your privacy and is committed to protecting your personal information.

This privacy notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with the General Data Protection Regulation (GDPR).

It applies to Mashariki Way’s business contacts, suppliers and professional advisors, parties with whom Mashariki Way conducts business (including clients, counterparties and potential clients and counterparties) and investors and any associated individuals. This website is not intended for children and we do not knowingly collect data relating to children.

The Mashariki Way Group can be made up of different legal entities, details of which can be provided to investors upon request at reasonable legal requirement grounds. This privacy notice is issued on behalf of the Mashariki Way Group so when we mention “Mashariki Way”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Mashariki Way Group responsible for processing your data.

Mashariki Way Limited is responsible for this website. For the purposes of the GDPR, and for European Union (EU) subjects to whom GDPR applies, the Mashariki Way company that you have dealings with is the controller of your personal information. This means that we are responsible for deciding how we hold and use personal information about you. We are required under the GDPR to notify you of the information contained in this privacy notice.

We have appointed a Data Protection Committee which is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Protection Committee by email.

You have the right to make a complaint at any time to the relevant data protection authority. We would, however, appreciate the chance to deal with your concerns before you approach the data protection authority, so please contact us in the first instance.

This notice applies to Mashariki Way’s business contacts, suppliers and professional advisors, parties with whom Mashariki Way conducts business (including clients, counterparties and potential clients and counterparties) and investors and any associated individuals. This notice does not form part of any contract of services. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

We reserve the right to update this privacy notice at any time. We may also notify you in other ways from time to time about the processing of your personal information.

2. DATA PROTECTION PRINCIPLES

We will comply with applicable data protection law. This says that the personal information we hold about you must be:

1. used lawfully, fairly and in a transparent way;

2. collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;

3. relevant to the purposes we have told you about and limited only to those purposes;

4. accurate and to the extent appropriate, kept up to date;

5. kept only as long as necessary for the purposes we have told you about; and

6. kept securely.

3. PERSONAL INFORMATION WE HOLD ABOUT YOU, PURPOSES AND LAWFUL BASIS FOR PROCESSING

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are more sensitive types of personal data which require a higher level of protection, known as ‘special categories’ of personal data under the GDPR. We do not collect any ‘special categories’ of personal data about you. Nor do we collect any information about criminal convictions and offences unless revealed by due diligence conducted to comply with a legal obligation or given to us in connection with our role, or potential role, as financial adviser in connection with a transaction, in order to comply with a legal obligation.

4. DATA SHARING

We share your personal information with third parties only as necessary, including third-party service providers and other entities in the Mashariki Way Group.

We require third parties to respect the security of your personal information and to treat it in accordance with the law.

We transfer your personal information outside the European Economic Area and when we do, you can expect a similar degree of protection in respect of your personal information.

5. DATA SECURITY

We have put in place appropriate measures to protect the security of your personal information.

Third parties will only process your personal information where they have agreed to treat the personal information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to access it. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

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

6. DATA RETENTION

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a business contact, supplier, professional advisor, counterparty with whom Mashariki Way conducts business (including client) or an investor of Mashariki Way we will retain and securely destroy your personal information in accordance with our data retention policy.

7. YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Your rights in connection with your personal information

Under certain circumstances, under the GDPR you have the right to:

· Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

· Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

· Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

· Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

· Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

· Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Your right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.