Privacy Policy

This Privacy Policy sets out how we, FINTECH Circle Ltd, collect, store and use information about you when you use or
interact with www.aibook.co.uk (our website) and where we otherwise obtain or collect information about you. This
Privacy Policy is effective from 15 Sept 2018.

Contents

  1. Summary
  2. Our details
  3. Information we collect when you visit our website
  4. Information we collect when you contact us
  5. Information we collect when you interact with our website
  6. Information we collect when you place an order on our website
  7. How we collect or obtain information about you from third parties
  8. Our use of automated decision-making and profiling
  9. Disclosure and additional uses of your information
  10. How long we retain your information
  11. How we secure your information
  12. Transfers of your information outside the European Economic Area
  13. Your rights in relation to your information
  14. Your right to object to the processing of your information for certain purposes
  15. Sensitive Personal Information
  16. Changes to our Privacy Policy
  17. Children’s Privacy
  18. Copyright, credit and logo

Summary

This section summarises how we obtain, store and use information about you. It is intended to provide a very general
overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full
sections of this Privacy Policy.

  • Data controller: FINTECH Circle Ltd
  • How we collect or obtain information about you:
    when you provide it to us (e.g. by contacting us, signing up as a new member, co-author, lecturer, student, placing
    an order on our website and by signing up to your e-newsletter and/or surveys),
    from your use of our website, using cookies and similar technologies, and
    occasionally, from third parties.
  • Information we collect: name, contact details, payment information e.g. your credit or debit card
    details (if applicable), IP address, information from cookies, information about your computer or device (e.g.
    device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when
    you view them and what you clicked on, the geographical location from which you accessed our website (based on your
    IP address), company name or business name (if applicable), VAT number (if applicable), and if you complete the
    joining form you provide us with the following information which we collect such as your linkedin ID, your
    title/position, your areas of expertise, membership in other networks, membership type, investor categorization,
    amount, objectives for joining, any comments and declaration of experience status.
  • How we use your information: for administrative and business purposes (particularly to contact
    you and process orders you place on our website), to improve our business and website, to fulfil our contractual
    obligations, to advertise our goods and services, to analyse your use of our website, and in connection with our
    legal rights and obligations.
    Disclosure of your information to third parties: only to the extent necessary to run our business, to our service
    providers, to fulfil any contracts we enter into with you, where required by law or to enforce our legal rights.
  • Do we sell your information to third parties (other than in the course of a business sale or purchase or
    similar event)
    : No
  • How long we retain your information: for no longer than necessary, taking into account any legal
    obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your
    information (e.g. your consent, performance of a contract with you or our legitimate interests as a business). For
    specific retention periods in relation to certain information which we collect from you, please see the main section
    below entitled How long we retain your information.
  • How we secure your information: using appropriate technical and organisational measures such as
    storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets
    Layer (SSL) technology, encrypting payments you make on or via our website using Secure Sockets Layer (SSL)
    technology, only granting access to your information where necessary.
  • Use of cookies and similar technologies: we use cookies and similar information-gathering
    technologies such as web beacons on our website including essential, functional, analytical and targeting cookies.
    For more information, please visit our cookies policy here: [insert link to cookies policy]
  • Transfers of your information outside the European Economic Area: in certain circumstances we
    transfer your information outside of the European Economic Area, including to the following countries: USA and
    Canada. Where we do so, we will ensure appropriate safeguards are in place for data transfers outside the European
    Economic Area e.g. the third parties we use who transfer your information outside the European Economic Area have
    self-certified themselves as compliant with the EU-U.S. Privacy Shield.
  • Use of automated decision making and profiling: we use automated decision making and profiling
    e.g. use of web analytics, cookies, web beacons or server logs analysis tools
  • Your rights in relation to your information
    • to access your information and to receive information about its use
    • to have your information corrected and/or completed
    • to have your information deleted
    • to restrict the use of your information
    • to receive your information in a portable format
    • to object to the use of your information
    • to withdraw your consent to the use of your information
    • to complain to a supervisory authority
  • Sensitive personal information: we do not knowingly or intentionally collect what is commonly
    referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to
    us. For more information, please see the main section below entitled Sensitive Personal Information.

Our details

The data controller in respect of our website is FINTECH Circle Ltd, Company Number: ?09141483 of 50 Liverpool Street,
London, EC2M 7PY. You can contact the data controller by writing to FINTECH Circle ltd, c/o Intelletec Ltd, The Office
Group, 50 Liverpool Street, London, England, EC2M 7PY or sending an email to info@fintechcircle.com
If you have any questions about this Privacy Policy, please contact the data controller.

Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure
and additional uses of your information.

Web server log information

We use third party servers to host our websites called:

Our website servers automatically log the IP address you use to access our website as well as other information about
your visit such as the pages accessed, information requested, the date and time of the request, the source of your
access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and
operating system.

Our servers are located in the United States and, accordingly, your information is transferred outside the European
Economic Area (EEA). For further information and information on the safeguards used, please see the section of this
privacy policy entitled Transfers of your information outside the European Economic Area.

Use of website server log information for IT security purposes

We and our third party hosting providers collect and store server logs to ensure network and IT security and so that the
server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised
access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by
detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting
provider to make, any attempt to identify you from the information collected via server logs.

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c)
of the General Data Protection Regulation).

Legal obligation: we have a legal obligation to implement appropriate technical and organisational
measures to ensure a level of security appropriate to the risk of our processing of information about individuals.
Recording access to our website using server log files is such a measure.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).

?Legitimate interests: we have a legitimate interest in using your information for the purposes of
ensuring network and information security.

Use of website server log information to analyse website use and improve our website

We use the information collected by our website server logs to analyse how our website users interact with our website
and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the
visit, the location of the visit and the operating system and browser used.
We use the information gathered from the analysis of this information to improve our website. For example, we use the
information gathered to change the information, content and structure of our website and individual pages based
according to what users are engaging most with and the duration of time spent on particular pages on our website.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).

?Legitimate interest: improving our website for our website users and getting to know our website
users’ preferences so our website can better meet their needs and desires.

Cookies and similar technologies

Cookies are data files which are sent from a website to a browser to record information about users for various
purposes.
We use cookies and similar technologies on our website, including essential, functional, analytical and targeting
cookies and web beacons. For further information on how we use cookies, please see our cookies policy which is available
here: Cookie Policy.

You can reject some or all of the cookies we use on or via our website by changing your browser settings or
non-essential cookies by using our cookie control tool, but doing so can impair your ability to use our website or some
or all of its features. For further information about cookies, including how to change your browser settings, please
visit www.allaboutcookies.org or see our
cookies policy.

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled
Disclosure and additional uses of your information.

Email

When you send an email to the email address displayed on our website we collect your email address and any other
information you provide in that email (such as your name, telephone number and the information contained in any
signature block in your email).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of
correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter
into a contract (Article 6(1)(b) of the General Data Protection Regulation).

?Reason why necessary to perform a contract: where your message relates to us providing you with goods
or services or taking steps at your request prior to providing you with our goods and services (for example, providing
you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

We use a third party email provider to store emails you send us. Our third party email provider is Google Mail (Gmail).
Their privacy policy is available here: https://policies.google.com/privacy

Emails you send us will be stored outside the European Economic Area on our third party email provider’s Gmail servers
in North America. For further information please see the section of this privacy policy entitled Transfers of your
information outside the European Economic Area.

Contact form

When you contact us using our contact form, we collect your name, email address, IP address and your request for
information. We also collect any other information you provide to us when you complete the contact form, including any
optional information, such as your company name, title, phone number or social media profile.

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact
form and we will not receive your enquiry.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of
correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter
into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods
or services or taking steps at your request prior to providing you with our goods and services (for example, providing
you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

Messages you send us via our contact form will be stored outside the European Economic Area on our third party hosting
and email provider’s servers in North America. Our third party email provider is Google/Gmail and our hosting provider
is WP Engine or Amazon Web Services AWS, both located in North America. Their privacy policy is available below:

Google’s privacy policy is available here: https://policies.google.com/privacy.

WP Engine’s privacy policy is available here: https://wpengine.co.uk/legal/privacy.

Amazon Web Services, AWS’ privacy policy is available here: https://aws.amazon.com/privacy.

We also use a third party contact form provider to store messages you send us. Our contact form provider is located in
North America. Their privacy policy is available here: https://www.wufoo.co.uk/privacy/. Messages you send to us via our
contact form will be stored outside the European Economic Area on our contact form provider’s servers in North America.
For further information about the safeguards used when your information is transferred outside the European Economic
Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic
Area.

Phone

When you contact us by phone, we collect your phone number and any information provided to us during your conversation
with us.

We do not record phone calls.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of
correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter
into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods
or services or taking steps at your request prior to providing you with our goods and services (for example, providing
you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

Information about your call, such as your phone number and the date and time of your call, is processed by our third
party telephone service provider, Vodafone, located in the European Economic Area. Their privacy policy is available
here: https://www.vodafone.co.uk/about-this-site/our-privacy-policy.

Information about your phone call will be stored by our third party telephone service provider within the European
Economic Area.

Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
?Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter
into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods
or services or taking steps at your request prior to providing you with our goods and services (for example, providing
you with information about such goods and services), we will process your information in order to do so).

Information we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website in accordance with
this section and the section entitled Disclosure and additional uses of your information.

E-Newsletter

When you sign up for our e-newsletter on our website or opt to receive news and offers from us by entering your name and
email address and clicking subscribe or by ticking a box at checkout indicating that you would like to receive our
e-newsletter, we collect your name and email address.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).

?Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using
the steps described above.

Transfer and storage of your information

We use a third party service to send out our e-newsletter and administer our mailing list, MailChimp. Their privacy
policy is available here: https://mailchimp.com/legal/privacy.

Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our
Mailchimp servers in North America. For further information about the safeguards used when your information is
transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your
information outside the European Economic Area.

Use of web beacons and similar technologies in emails

We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of
engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates
which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so.

For more information on how we use web beacons in our e-newsletter emails, see our cookies policy which is available
here: Cookie Policy

For more information about our third party mailing list provider and they use web beacons, please see their privacy
policy which is available here: https://mailchimp.com/legal/privacy.

Registering on our website

When you register and create an account on our website (where applicable), we collect the following information: name,
email address, IP address and any other information you provide to us when you complete the registration form, including
your company name, title and country.

If you do not provide the mandatory information required by the registration form, you will not be able to register or
create an account on our website.

Legal basis for processing: necessary to perform a contract or to take steps at your request prior to
entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: creating an account on our website is necessary to allow
you to access the goods and services you have purchased from us

Transfer and storage of your information

Information you submit to us via the registration form on our website will be stored outside the European Economic Area
on our third party hosting provider’s servers in North America. Our third party hosting provider is WP Engine and AWS
located in North America. Their privacy policy is available below:

For further information about the safeguards used when your information is transferred outside the European Economic
Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic
Area.

Information we collect when you place an order on our website

We collect and use information from individuals who place an order on our website in accordance with this section and
the section entitled Disclosure and additional uses of your information.

Information collected when you place an order

Mandatory information

When you place an order for goods or services on our website, we collect your name, email address, billing address,
shipping address, company name (if applicable), VAT number (if applicable), and which product you want to purchase.

If you do not provide this information, you will not be able to purchase goods or services from us on our website or
enter into a contract with us.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data
Protection Regulation).

Reason why necessary to perform a contract: we need the mandatory information collected by our checkout
form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including
sending you receipts and order confirmations.

Processing your payment

After you place an order on our website you will need to make payment for the goods or services you have ordered. In
order to process your payment we use the third party payment processor PayPal.

Paypal collects, uses and processes your information, including payment information, in accordance with their privacy
policies. You can access their privacy policy via the following link: https://www.paypal.com/en/webapps/mpp/ua/privacy-full.

Transfer and storage of your information

Paypal is located in North America. Information relating to the processing of your payment is stored outside the
European Economic Area on Paypal’s servers in North America.

For further information about the safeguards used when your information is transferred outside the European Economic
Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic
Area.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data
Protection Regulation).

Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods
or services you have ordered from us.

Marketing communications

At checkout you will have the option of receiving marketing communications from us.

Our goods and services

You can opt in to receiving marketing communications from us in relation to our goods and services by email, and text
message by ticking a box indicating that you would like to receive such communications.

We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: you give your consent to us sending you information about our goods and services by signing up
to receive such information in accordance with the steps described above.

Transfer and storage of your information

We use a third party service to administer our mailing list, MailChimp.

Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our third
party mailing list provider’s servers in North America. For further information about the safeguards used when your
information is transferred outside the European Economic Area, see the section of this privacy policy below entitled
Transfers of your information outside the European Economic Area.

Use of web beacons and similar technologies in emails

We use technologies such as web beacons (small graphic files)] in the emails we send to allow us to assess the level of
engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates
which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so.

For more information on how we use web beacons in our emails, see our cookies policy which is available here: Cookie Policy.

For more information about our third party mailing list provider and how they use web beacons, please see their privacy
policy which is available here: https://mailchimp.com/legal/privacy.

Information collected or obtained from third parties

This section sets out how we obtain or collect information about you from third parties.

Information received from third parties

Generally, we do not receive information about you from third parties.

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name and contact details, but will include any
additional information about you which they provide to us.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter
into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where a third party has passed on information about you to
us (such as your name and email address) in order for us to provide services to you, we will process your information in
order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may
be).

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: where you have asked that a third party to share information about you with us and the purpose
of sharing that information is not related to the performance of a contract or services by us to you, we will process
your information on the basis of your consent, which you give by asking the third party in question to pass on your
information to us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).

Legitimate interests: where a third party has shared information about you with us and you have not
consented to the sharing of that information, we will have a legitimate interest in processing that information in
certain circumstances.

For example, we would have a legitimate interest in processing your information to perform our obligations under a
sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the
performance of our obligations under our sub-contract.

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of
our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and
pursue any such potential infringement.

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that
information, we will delete your information.

Information obtained by us from third parties

In certain circumstances (for example, to verify the information we hold about you or obtain missing information we
require to provide you with a service) we will obtain information about you from certain publicly accessible sources,
both EU and non-EU, such as Companies House, business directories, media publications, social media, and websites
(including your own website if you have one).

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter
into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where you have entered into a contract or requested that we
enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in
order to enable us to understand your business and provide services to you or services to a sufficient standard.

For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to
send you information by email if we do not possess the information or we need to confirm that we have recorded your
email address correctly.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).

Legitimate interests: in certain circumstances, we will have a legitimate interest in obtaining
information about you from public and private sources. For example, if you have infringed or we suspect that you have
infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information about you
from such sources in order to investigate and pursue any suspected or potential infringement.

Our use of automated decision-making and profiling

We use profiling on our website. We do not consider that this has any legal effect on you or similarly significantly
affects you.
You have the right to object to our use of profiling described in this section. You can do that by opting-out of cookies
and similar technologies in accordance with the method described in the relevant section below. If you do not want us to
process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit
our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.

You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them)
and how to opt out from them in our cookies policy, which is available here: Cookie Policy.

Automated decision making

Automated decision making is decision making by technological means (i.e. by a machine) without human involvement. We
currently do not use automated decision making.

Profiling

Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular
to analyse or predict things like your personal preferences, interests, behaviour, or location.

Use of profiling for web analytics

Our web analytics service, Google Analytics collects information such as your location (based on your IP address) and
your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on. We
will only process information from cookies if you have consented to us setting cookies on your computer in accordance
with our cookies policy ([insert link to cookies policy]).

Logic involved: by automatically analysing and categorising information such as the location (based on
IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a
better understanding of what our website visitors want (in terms of the content of our website and our products), how to
improve our website and how to advertise and market our services to them.

Significance and envisaged consequences: cookies will be used to track and store information about your
behaviour and device on our website (unless you have opted out from receiving such cookies by using our cookie
management tool) and your location will be analysed based on your IP address.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation). ?Legitimate interest: improving our website for our website users and getting to know our website users’
preferences so our website can better meet their needs and desires.

Use of profiling in marketing emails

We use web beacons in our marketing emails to analyse who opens our emails and what actions they take (for example, what
they click on). We will only process information from web beacons if you have consented to their use in accordance with
our cookies policy ([insert link to cookies policy]).

Logic involved: By analysing how our email recipients respond to our emails, we are able to improve the
content and effectiveness of our emails and gauge who is most interested.

Significance and envisaged consequences: your behaviour when you open our emails will be tracked using
small gif files (web beacons), including open rates, and click through rates.

How to object: You can object to our use of web beacons by emailing info@fintechcircle.com.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).

Legitimate interest: analysing the level of engagement and effectiveness of our marketing emails and
content

Disclosure and additional uses of your information

This section sets out the circumstances in which we disclose information about you to third parties and any additional
purposes for which we use your information.

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us
with running our business. These include the following:

Apart from Vodafone which are located in the UK, our service providers are located in the United States.

Your information will be shared with these service providers where necessary to provide you with the service you have
requested, whether that is accessing our website or ordering goods and services from us.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).

Legitimate interest relied on: where we share your information with these third parties in a context
other than where is necessary to perform a contract (or take steps at your request to do so), we will share your
information with such third parties in order to allow us to run and manage our business efficiently.

Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior
to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: we may need to share information with our service providers
to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into
a contract with you.

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to third parties such as Google Inc. Google collects information through our use of Google
Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a
number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated
and anonymised basis. To find out more about what information Google collects, how it uses this information and how to
control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).

Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms
of Service (https://www.google.com/analytics/terms/us.html).

You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout.

Transfer and storage of your information

Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United
States of America.

For further information about the safeguards used when your information is transferred outside the European Economic
Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic
Area.]

Sharing your information with third parties, which are either related to or associated with the running of our business,
where it is necessary for us to do so. These third parties include our accountants, advisors, affiliates, business
partners, independent contractors, and insurers. Further information on each of these third parties is set out below.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).

Legitimate interest: running and managing our business efficiently.

Accountants

We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our
accountants for the purpose of completing tax returns and our end of year accounts. Our accountants are located in the
European Economic Area.

Advisors

Occasionally, we obtain advice from advisors, such as financial advisors, lawyers and public relations professionals. We
will share your information with these third parties only where it is necessary to enable these third parties to be able
to provide us with the relevant advice. Our advisors are located in the European Economic Area.

Affiliates

Affiliates are individuals or entities we work with to promote our business by various means, including by advertising
our services on their websites, for example. Affiliates will share information with us and we will share information
with them where you have expressed an interest in our products or services. Our affiliates are located both inside and
outside of the European Economic Area.

Business partners

Business partners are businesses we work with which provide goods and services which are complementary to our own or
which allow us to provide goods or services which we could not provide on our own. We share information with our
business partners where you have requested services which they provide whether independently from, or in connection with
or own services. Our affiliates are located both inside and outside of the European Economic Area.

Independent contractors

We use independent contractors in our business. Your information will be shared with independent contractors only where
it is necessary for them to perform the function we have hired them perform in relation to our business. Our independent
contractors are located in the UK.

Insurers

We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or
potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.
Our insurers are located in the UK.

Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or
acquisition by us, a merger or similar business combination event, whether actual or potential.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).

Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person
in order to allow such a transaction to take place.

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to
contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that fraud or
a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an
incident in some way.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).

Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

In connection with the enforcement or potential enforcement of our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including,
for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are
contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or
non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).

Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to
resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).

Legitimate interest(s): resolving disputes and potential disputes.

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example,
we may need to disclose your information pursuant to a court order or subpoena if we receive one.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data
Protection Regulation).

Legal obligation(s): legal obligations to disclose information which are part of the laws of England
and Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an
international agreement which the United Kingdom has signed).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).

Legitimate interest: where the legal obligations are part of the laws of another country and have not
been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these
obligations.

How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible.
Where that has not been possible, we have set out the criteria we use to determine the retention period.

Retention periods

Server log information: we retain information on our server logs for 6 years.

Order information: when you place an order for goods and services, we retain that information for six
years following the end of the financial year in which you placed your order, in accordance with our legal obligation to
keep records for tax purposes.

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by
email or via our contact form or by phone, we will retain your information for as long as it takes to respond to and
resolve your enquiry, and for 12 further months after which point we will delete your information.

E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you
remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes
earlier.

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the
following:

  • the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue
    to store that information in order to continue to perform our obligations under a contract with you or to contact
    you in the future);
  • whether we have any legal obligation to continue to process your information (such as any record-keeping
    obligations imposed by relevant law or regulation);
  • whether we have any legal basis to continue to process your information (such as your consent);
  • how valuable your information is (both now and in the future);
  • any relevant agreed industry practices on how long information should be retained;
  • the levels of risk, cost and liability involved with us continuing to hold the information;
  • how hard it is to ensure that the information can be kept up to date and accurate; and
  • any relevant surrounding circumstances (such as the nature and status of our relationship with you).

How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against
unauthorised or unlawful use and accidental loss or destruction, including:

  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality
    restrictions
  • where appropriate, and on an anonymised basis wherever possible;
  • using secure servers to store your information;
  • verifying the identity of any individual who requests access to information prior to granting them access to
    information;
  • using Secure Sockets Layer (SSL) software to encrypt any payment transactions you make on or via our website.

Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the
internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other
form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

Transfers of your information outside the European Economic Area

Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out
below. We will also transfer your information outside the EEA or to an international organisation in order to comply
with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do
so, we will ensure appropriate safeguards and protections are in place.

Server log information

Information collected when you visit our website is transferred outside of the EEA and stored on the servers of our
third party hosting companies, AWS and WP Engine. You can access their privacy policy here:

Country of storage: United States of America. This country is not subject to an adequacy decision by
the European Commission.

Safeguard(s) used: AWS and WP Engine have self-certified their compliance with the EU-U.S. Privacy
Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification
mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the
General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S.
Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

Contact form

Information you submit to us via our contact form is transferred outside the EEA and stored on our third party hosting
and email provider’s servers. Our hosting provider are WP Engine and AWS, our form provider is Wufoo and our email
provider is Google/Gmail. You can access their privacy policy here:

Country of storage: United States of America. This country is not subject to an adequacy decision by
the European Commission.

Safeguard(s) used: AWS, WP Engine, Wufoo and Google have self-certified their compliance with the
EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an
approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under
Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the
adequacy of the EU-U.S. Privacy Shield here:
http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

Email

Information you submit to us by email is transferred outside the EEA and stored on our third party email provider’s
servers. Our third party email provider is: Google. You can access their privacy policy here:

https://policies.google.com/privacy

Country of storage: United States of America. This country is not subject to an adequacy decision by
the European Commission.

Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is
available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification
mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the
General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S.
Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

E-Newsletter

Information you submit to us when you sign up for our e-newsletter is transferred outside the EEA and stored on our
third party mailing list provider’s servers. Our third party mailing list provider is: Mailchimp. You can access their
privacy policy here:
https://mailchimp.com/legal/privacy.

Country of storage: United States of America. This country is not subject to an adequacy decision by
the European Commission.

Safeguard(s) used: Mailchimp has self-certified its compliance with the EU-U.S. Privacy Shield which is
available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification
mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the
General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S.
Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

Online Surveys

Information you submit to us when you sign up for our online surveys is transferred outside the EEA and stored on our
third party mailing list provider’s servers. Our third party mailing list provider is: Survey Monkey. You can access
their privacy policy here: https://www.surveymonkey.com/mp/legal/privacy-policy.

Country of storage: United States of America. This country is not subject to an adequacy decision by
the European Commission.

Safeguard(s) used: Survey Monkey has self-certified its compliance with the EU-U.S. Privacy Shield
which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification
mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the
General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S.
Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

Google Analytics

Information collected by Google Analytics (your IP address and actions you take in relation to our website) is
transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/

Country of storage: United States of America. This country is not subject to an adequacy decision by
the European Commission.

Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is
available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification
mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the
General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S.
Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which
you can exercise by writing to FINTECH Circle ltd, c/o Intelletec Ltd, The Office Group, 50 Liverpool Street, London,
England, EC2M 7PY or sending an email to info@fintechcircle.com:

  • to request access to your information and information related to our use and processing of your information;
  • to request the correction or deletion of your information;
  • to request that we restrict our use of your information;
  • to receive information which you have provided to us in a structured, commonly used and machine-readable format
    (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third
    party data controller);
  • to object to the processing of your information for certain purposes (for further information, see the section
    below entitled Your right to object to the processing of your information for certain purposes); and
  • to withdraw your consent to our use of your information at any time where we rely on your consent to use or
    process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our
    use and processing of your information on the basis of your consent before the point in time when you withdraw your
    consent.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint
with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an
alleged infringement of the General Data Protection Regulation.

For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact
details of which are available here: https://ico.org.uk/global/contact-us.

Further information on your rights in relation to your personal data as an individual

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further
information about your rights in relation to your information, including any limitations which apply, please visit the
following pages on the ICO’s website:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/;
and
https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/.

You can also find out further information about your rights, as well as information on any limitations which apply to
those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection
Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf.

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your
identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or
general unauthorised access to your information.

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that
information.
If it is not possible to identity you from such information, or if we have insufficient information about you, we may
require original or certified copies of certain documentation in order to be able to verify your identity before we are
able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if
and when you make such a request.

Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you may exercise in the same way as you may
exercise by writing to FINTECH Circle ltd, c/o Intelletec Ltd, The Office Group, 50 Liverpool Street, London, England,
EC2M 7PY or sending an email to info@fintechcircle.com:

  • to object to us using or processing your information where we use or process it in order to carry out a
    task in the public interest or for our legitimate interests
    , including ‘profiling’ (i.e. analysing or
    predicting your behaviour based on your information) based on any of these purposes; and
  • to object to us using or processing your information for direct marketing purposes (including any
    profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

  • clicking the unsubscribe link contained at the bottom of any marketing email we send to you and
    following the instructions which appear in your browser following your clicking on that link;
  • sending an SMS message containing only the words “OPT OUT” in reply to any marketing
    communication we send by text message;
  • sending an email to info@fintechcircle.com, asking
    that we stop sending you marketing communications or by including the words “OPT OUT”.

For more information on how to object to our use of information collected from cookies and similar technologies, please
see the section entitled How to accept or reject cookies in our cookies policy, which is available here: Cookie Policy

Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin,
political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric
information for the purpose of uniquely identifying an individual, information concerning health or information
concerning a natural person’s sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit
sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to
have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data
Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at
the beginning of it. Our processing of your information will be governed by the practices set out in that new version of
the Privacy Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different
purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by
posting a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information
before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from
the purposes for which we originally collected it.

Children’s Privacy

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection
Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do
not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit
information of any kind from persons under the age of 18.

It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of
a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do
so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such
parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of
information about persons under the age of 18, please do so by sending an email to info@fintechcircle.com.

Copyright, credit and logo

This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant
template provided by GDPR Privacy Policy. For further information, please visit https://gdprprivacypolicy.org

The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around
the world and copyright protection software. All intellectual property rights in this document are reserved.

Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy
policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.

Check out the online HTML CheatSheet here and save the link because you might need it while composing content for a web page.