Website Privacy Policy

OUR COMMITMENT TO PRIVACY

October 2024

Your privacy is important to Patient Square Capital, L.P. and its affiliates (together, “Patient Square,” “our,” “us,” “we” or “company”). To better protect your privacy, we are providing information explaining our online information practices, including the manner in which we process your personal information (which we may also refer to as personally identifiable information or personal data) and the measures that Patient Square takes to preserve the privacy and security of your personal information. 

This Website Privacy Policy (this “Privacy Policy”), together with the California Website Privacy Policy and the EEA-UK Privacy Policy, describes how and why we gather and use information in connection with this website and where this Privacy Policy is posted (the “website”) and your communication with us in relation to the website. Please read this Privacy Policy carefully.

Visitors that are residents of California should refer to our California Website Privacy Policy supplement below.

Visitors that are located in the United Kingdom (“UK”), the European Union (“EU”) or the European Economic Area (“EEA”), or whose personal data is otherwise subject to EU and/or UK data protection laws (“EEA & UK Visitors”) should refer to our EEA-UK Privacy Policy. 

THE PERSONAL INFORMATION WE MAY COLLECT

The types of personal information we collect about you depend on the nature of your interaction with us and our reasons for collecting your personal information. The categories of personal information we collect include the following:

• Your basic information: your name, prefix/title, gender, age, and/or date of birth. 
• Contact information: your email address, physical address, and/or phone number if provided.   
• Information we obtain by automated means: information about your computer or device, IP address, content and traffic data, how you use this website, the length of time spent on this website, and the pages accessed while visiting the website.

Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to websites you visit, indicating that you do not wish to be tracked. At this time, we do not currently respond to DNT Signals.

We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.

HOW WE OBTAIN YOUR PERSONAL INFORMATION

In connection with forming and operating our website, we may collect and maintain your personal information from the following sources:

• information from your communications with us in connection with our website, including if provided via the “Contact” page on this website; 
• information captured on our website, including any information captured via cookies or similar technology (please see the “Cookies” section below for information about how we use such technologies); 
• information obtained through communications with us, such as information obtained through telephone calls (which may be recorded for regulatory purposes), video communications and other verbal communications, as well as written correspondence, including when you provide it to us in online correspondence via email; and/or information about you from third parties or publicly available sources provided or collected.

HOW WE USE YOUR PERSONAL INFORMATION

We may use your personal information for one or more of the following business or commercial purposes:

Purpose	Legal Basis (relevant to the EEA-UK Privacy Policy)
To conduct business with you or to provide you with the services you have requested, including responding to your enquiries and requests and providing you with support.	Contractual necessity; and/or our legitimate interest in operating our business and providing investment services.
To communicate with you, to operate, schedule and facilitate meetings (in-person and online) and to administer your participation in any of our events.	Our legitimate interest in operating our business and providing investment services; and/or consent.
To verify your identity (including to conduct anti-money laundering or KYC checks and to enable you to access our offices) or to evaluate a potential investor, business partner or supplier.	Our legitimate interest in operating our business and providing investment services; contractual necessity; legal requirement; and/or consent.
To protect against, identify and prevent fraud, money-laundering, cyber-attacks, theft of our property, other threats to the safety, security and integrity of our website, investor portals, products and services, databases, technology assets or our business, and other malicious, or unlawful activity.	Legal requirement; and/or our legitimate interest in operating our business and providing investment services securely and safely.
To conduct conflicts checks.	Legal requirement.
To process and administer details associated with your investment and service your requests, and to offer and improve our services.	Our legitimate interest in operating our business; and/or consent.
Complying with our legal obligations and corporate governance practices, which may require recording or monitoring telephone calls or other communications with you.	Legal requirement; our legitimate interest in operating our business; and/or consent.
Litigation management and conducting internal audits and investigations.	Legal requirement; and/or our legitimate interest in operating our business.
To audit and verify the quality and effectiveness of our services and compliance.	Our legitimate interest in operating our business.
To keep a record of and manage your relationship with us.	Our legitimate interest in operating our business and providing services; and/or legal requirement.
To provide advertising and marketing services, including make suggestions or recommendations to you, or to provide you with updates or other information, about our business and services that may be of interest to you.	Our legitimate interest in operating our business.
To obtain advice from our professional advisers, including financial advisers and lawyers.	Our legitimate interest in operating our business.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about the website users is among the assets transferred.	Our legitimate interest in operating our business.
To administer, protect and improve our business and this website.	Our legitimate interest in operating our business.
For any other purpose that has been notified in writing.	Consent.

We may process your personal information on more than one legal basis depending on the specific purpose for which we are using your personal information.

DISCLOSURE OF PERSONAL INFORMATION

To the extent that you provide us with any personal information through or in connection with this website, we may use such information for Patient Square’s business purposes as set forth in this Privacy Policy, but will not disclose any personal information about you to anyone, except as permitted or required by law or regulation and to service providers as discussed below. 

We may share your personal information with affiliates and agents and certain service providers and professional advisors, including: (i) fund managers, depositories, administrators, placement agents, custodians, investment advisors and other fund administrators; (ii) service providers, recruitment firms, consultants IT and data security providers and/or data hosting providers; (iii) our lawyers, auditors and other professional advisors; and (iv) regulators, law enforcement and other government bodies, in order to provide services on our behalf and as necessary to fulfil the purposes set out in this Privacy Policy. We seek assurances that our standards for data security are met by anyone who enters into an agreement providing a service to, or for us.

We may also share your personal information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding, or other disposition of all or a portion of our business, assets or shares.

We reserve the right to disclose your personal data as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition, we may disclose your personal data to the new owner of the relevant business and their advisors on the basis of our legitimate interest.

The website may contain links to other websites which are not hosted or operated by us. These websites may use automated means to collect information regarding your use of the websites. This information is subject to the privacy policies or notices of the provider’s website.

SECURITY AND RETENTION

We are committed to protecting the personal data you entrust to us. We adopt robust and appropriate technologies and policies, so the personal data we have about you is protected to the extent possible from unauthorized access and improper use. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we make an effort to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through our website; any transmission of information or data by you to or through this website is at your sole risk.We review the personal data we hold periodically and delete it securely. We will keep your personal data only for as long as is reasonably necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required by law. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal data, please contact [email protected].

CAPACITY

You represent to Patient Square that you have the authority to visit this website according to the Terms of Use. This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.

COOKIES

Information regarding how you access this website (e.g., browser type, access times and Internet Protocol (IP) address) and your hardware and software is automatically collected through the use of cookies (a small text file placed on your hard drive) or other technologies or tools. This information is used to improve website performance and for our business purposes, including to help provide you with a better experience when you browse the website. In accordance with applicable privacy laws, including the GDPR, we will ask for your consent to use cookies that are not necessary for providing services or the website’s basic functionality. You may opt-in to accept cookies automatically by changing the settings on your browser. If you opt-out of certain cookies, you may not be able to access certain parts of this website. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences.

Subject to your consent, the website will place the cookies listed below:

Cookie name	Value	Domain	Type/Purpose	Duration
_ga*	GA1.1.1020836950.1651493308	.patientsquarecapital.com	This cookie is a Google Analytics persistent cookie which is used to distinguish unique users	2 years
_gid	GA1.1.1020836950.1651493308	.patientsquarecapital.com	This cookie is a Google Analytics persistent cookie which is used to distinguish unique users	24 hours
_gat_gtag_UA_179971678_2	GA1.2.1545645047.1657561937	.patientsquarecapital.com	This cookie is installed by Google Analytics. The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the website is doing. The data collected including the number visitors, the source where they have come from, and the pages visited in an anonymous form.	1 minute
cookie_notice_accepted	1 TRUE	.patientsquarecapital.com	This cookie is used to throttle request rate. These are third party cookies that are placed on your device to allow us to use the Google Analytics service. These cookies are used to collect information about how visitors use our website. We use this information to compile reports and to help us improve the website	1 year

You may access any personally identifiable information we have about you by contacting [email protected].

NOTIFICATION OF CHANGES

We reserve the right to amend this Privacy Policy from time to time and for any reason, in our sole discretion, without notice, by updating this Privacy Policy. Accordingly, users are strongly encouraged to review our Privacy Policy regularly. If we decide to change our Privacy Policy, we will post those changes so our users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page. We will use information only in accordance with the version of the Privacy Policy under which the information was collected. Your continued access or use of this website following the posting of changes to this Privacy Policy means that you accept such revisions, changes and/or amendments. If you object to any of the changes to this Privacy Policy, please stop accessing this website. Please check this page frequently and review any changes to this Privacy Policy carefully so you are aware of any changes, as they are binding on you.

CONTACT US

If you have any questions or concerns about this Privacy Policy, wish to exercise any rights, to access this Privacy Policy in an alternative format, submit requests, or appeal any of our decisions in connection with this Privacy Policy (each, a “Communication”), please contact [email protected].

We verify Communications by matching information provided in or in connection with your Communication to information contained in our records. Depending on the sensitivity of the Communication and the varying levels of risk in responding to such Communications (for example, the risk of responding to fraudulent or malicious communications), we may request further information or your investor portal access credentials, if applicable in order to verify your Communication.

CALIFORNIA WEBSITE PRIVACY POLICY

LAST UPDATED: October 2024

This California Website Privacy Policy supplements the Website Privacy Policy with respect to specific rights granted under the California Consumer Privacy Act of 2018, as amended, (the “CCPA”), to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in the Website Privacy Policy. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.

What does this California Website Privacy Policy apply to?

This California Website Privacy Policy applies solely to (i) your interactions with us through our website (as defined below) and (ii) if you are seeking employment with us. If you provide personal information to use through another means (e.g., as an investor) you will receive a separate privacy notice and that notice will govern that personal information.

What information do we collect about you?

We collect limited types of personal information through our website and investor reporting portals, as well as through other electronic communications (e.g., emails), as applicable (collectively, the “website”). The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we have collected from individuals on this website over the last twelve (12) months include the following:

Category	Examples	Collected
A. Identifiers	Name, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and driver’s license or state identification card number).	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income and assets).	YES
C. Protected classification characteristics under California or federal law	Date of birth, citizenship and birthplace.	YES
D. Commercial information	Account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s).	YES
E. Biometric information	Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contains identifying information.	NO
F. Internet or other similar network activity	Use of our website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries.	YES
G. Geolocation data	Physical location or movements.	NO
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	YES
K. Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO
L. Sensitive Personal Information (see further information on use of sensitive personal information below)	Social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.	YES; as to the following types of information: account log-in, financial account in combination with any required security or access code password, or credentials allowing access to an account only.

We do not collect or use sensitive personal information other than:

• To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
• As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
• As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
• For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
• To perform services on behalf of our business;
• To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; and
• To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

How do we obtain your personal information?

We collect personal information for the business or commercial purposes and from the sources set forth in “The Personal Information We May Collect” and “How We Obtain Your Personal Information,” respectively, in the Privacy Policy above. We retain the categories of personal information set forth above in “What information do we collect about you?” section of this California Website Privacy Policy only as long as is reasonably necessary for those purposes set forth above in “How do we use your personal information?”, except as may be required under applicable law, court order or government regulations.

Who do we disclose your personal information with?

We do not share (i.e., disclose to a third party for the purpose of cross-context behavioral advertising) or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.

Within the last twelve (12) months, we have disclosed personal information collected in connection with this website for a business purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Personal Information Category	Category of Third-Party Recipients
A. Identifiers	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
C. Protected classification characteristics under California or federal law	N/A
D. Commercial information	N/A
E. Biometric information	N/A
F. Internet or other similar network activity	Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents.
G. Geolocation data	N/A
H. Sensory data	N/A
I. Professional or employment-related information	N/A
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	N/A
K. Inferences drawn from other personal information	N/A
L. Sensitive Personal Information	Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents.

How do we keep your personal information secure?

We consider the protection of personal information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.

Your rights under the CCPA

Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal information specific to you. Such information includes:

• the categories of personal information we collected about you;
• the categories of sources from which the personal information is collected;
• our business or commercial purpose for collecting such personal information;
• the categories of third parties to whom we disclose the personal information;
• the specific pieces of personal information we have collected about you; and
• whether we disclosed your personal information to a third party, and, if so, the categories of personal information that each recipient obtained.

Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.

Contact us

For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below. 

• Email us at the following email address: [email protected] outlining your request.
• Submit your request, along with your contact information, via our contact form at: https://www.patientsquarecapital.com/california-consumer-privacy-act-rights

If you would like to contact us by telephone without incurring telephone charges, please submit your request and telephone number either (1) through the online form above or (2) by email at the above address, and we will call you between regular business hours. We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.

Please contact [email protected] with any questions about this California Website Privacy Policy.

EEA-UK PRIVACY POLICY

Last updated: October 2024

OUR COMMITMENT TO PRIVACY

Your privacy is important to Patient Square Capital, L.P. and its affiliates (together, “Patient Square,” “our,” “us,” “we” or “company”). To better protect your privacy, we are providing information to explain our personal data handling practices.

This EEA-UK Privacy Policy supplements the Privacy Policy with respect to our use of personal data which is subject to EEA-UK Privacy Laws and does not apply to any processing of personal data by or on behalf of Patient Square that is covered by a more specific privacy notice (including, without limitation, the Limited Partner Privacy Notice). 

For the purposes of this EEA-UK Privacy Policy, “EEA-UK Privacy Laws” mean all applicable laws and regulations relating to privacy, protection or processing of personal data in the European Economic Area (“EEA”), European Union (“EU”) and UK, including the General Data Protection Regulation (Regulation (EU) 2016/679) (“EU GDPR”), the EU GDPR as it forms part of the laws of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union Withdrawal Act 2018 (“UK GDPR”), and including in respect of the foregoing any implementing or successor legislation and any amendments or re-enactments. The terms “controller”, “data subject”, “personal data”, “processor”, “process” and “processing” shall be interpreted in accordance with the applicable EEA-UK Privacy Laws.

You do not need to take any action as a result of this EEA-UK Privacy Policy, but you may have certain rights as described below.

Information required to be disclosed under EEA-UK Data Protection Laws regarding the collection of your personal data that is not set forth in this EEA-UK Privacy Policy is otherwise set forth in the Privacy Policy. To the extent there is any conflict in respect of any processing subject to EEA-UK Data Protection Laws between the general Privacy Policy and this EEA-UK Privacy Policy, this EEA-UK Privacy Policy shall apply. Please read this EEA-UK Privacy Policy carefully.

For the purposes of applicable EEA-UK Privacy Laws, Patient Square and its affiliated general partners and managing members will each be a controller of any personal data collected by us when you interact with us in the ways described above (e.g., when you visit our website, etc.). In simple terms, this means that we: (i) “control” the personal data that we collect from you or other sources, including making sure that it is kept secure; and (ii) make certain decisions on how to use and protect your personal data. If you have any questions regarding our use of your personal data, or this EEA-UK Privacy Policy, please contact [email protected].

ANY ADDITIONAL PERSONAL DATA WE MAY COLLECT

As discussed in the “Personal Information we may collect” section of the Privacy Policy, the types of personal data we collect about you depends on the product or service you have requested from us and/or the nature of your interaction with us. 

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), although there may be limited circumstances where we need to collect this type of personal data, or it is collected incidentally. Nor do we collect any information about criminal convictions and offences.

If we require your personal data due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data. Failure to provide this information means that we cannot provide our services or products to you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

HOW WE OBTAIN YOUR PERSONAL DATA

In connection with forming and operating our website, we collect and process your personal data from you and other third parties and/or publicly available sources listed in the “How do we obtain your personal information” section in the Privacy Policy above.

HOW WE USE YOUR PERSONAL DATA

We rely on various legal bases under the EEA-UK Privacy Laws in order to process your personal data, as we have set forth in the section titled “How we use your personal information” in the Privacy Policy.

Note that we may process your personal data on more than one legal basis depending on the specific purpose for which we are using your personal data. We may also process personal data for any other purpose that has been notified to you, or that has been agreed in writing with you. 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

No solely automated decision-making, including profiling, is used when processing your personal data.

DISCLOSURE AND TRANSFER OF PERSONAL DATA

We will share your personal data with our affiliates and certain providers as necessary to fulfill the purposes set out in the Privacy Policy, as permitted by law or regulation, including the EEA-UK Privacy Laws.

To the extent your personal data is transferred to a Non-Equivalent Country (as defined below), such transfers will only be made in accordance with EEA-UK Privacy Laws. For the purposes of this EEA-UK Privacy Policy, “Non-Equivalent Country” means a country or territory other than (i) a member state of the EEA; (ii) the UK; or (iii) a country or territory which has at the relevant time been decided by the European Commission or the Government of the UK (as applicable) in accordance with the applicable EEA-UK Privacy Laws to ensure an adequate level of protection for personal data.

SECURITY AND RETENTION OF PERSONAL DATA

We take measures to ensure the security of your personal data as described in the “Security and Retention” section in the Privacy Policy above.

CAPACITY

This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal data from anyone under the age of 18 without parental consent. If we learn we have collected or received personal data from an individual under the age of 18, we will delete that information.

COOKIES

Information regarding the cookies we use is described in the “Cookies” section in the Privacy Policy above.

YOUR RIGHTS

Under certain circumstances, by law, you have the right to access the personal data we hold about you, and there are a number of ways you can control the way in which and what information we store and process about you. To exercise these rights and controls, please contact [email protected].  

• Access: You have the right to ask for a copy of the personal data that we hold about you free of charge. However, we may charge a “reasonable fee,” if we think that your request is excessive, to help us cover the costs of locating the information you have requested. 
• Correction: You may notify us of changes to your personal data if it is inaccurate or it needs to be updated.
• Deletion: If you think that we should not be holding or processing your personal data anymore, you may request that we delete it. Please note that this may not always be possible due to legal obligations.  
• Restrictions on use: You may request that we stop processing your personal data (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal data, override your own rights.
• Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
• Portability: If you wish to transfer the personal data that we hold and process about you on the legal ground of contractual necessity to another organization (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
• Withdrawal of consent: If you previously gave us your consent to allow us to process your personal data for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent. If you do not do so, we may continue to rely upon that previous consent to keep using and processing your personal data in the same way.

These rights are not absolute and in certain circumstances their exercise may not be possible including when personal data must be maintained to comply with applicable laws. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

NOTIFICATION OF CHANGES

We reserve the right to amend this EEA-UK Privacy Policy from time to time by updating this EEA-UK Privacy Policy. If we decide to change our EEA-UK Privacy Policy, we will post those changes so our users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal data or use any collected information in a manner different from that stated at the time it was collected, we will notify applicable users. We will use information only in accordance with this EEA-UK Privacy Policy under which the information was collected.

CONTACT US

If you have any questions or concerns about this EEA-UK Privacy Policy, please contact [email protected].

COMPLAINTS

Should you wish to lodge a complaint with regards to how your personal data has been processed by us, please contact your local supervisory authority. In the UK, this is the Information Commissioner’s Office – https://ico.org.uk/global/contact-us. In the EU, this is the local supervisory authority in the EU Member State of your habitual residence, place of work, or place of the infringement, concern or complaint.

We would, however, appreciate the opportunity to address your concerns before you approach the relevant supervisory authority, so please contact us in the first instance.