CREATIVE TECHNOLOGIES LIMITED

This Privacy Policy is designed to help you understand what information we gather and process about you ("personal data"), why and how we use it, and with whom we share it. It also sets out the rights you have in relation to your information and how you may contact us for your queries.

DEFINITIONS USED IN THE PRIVACY POLICY CAN BE FOUND HERE

“Client” means an investor in our products or a recipient of our services, who may be an individual investor, or an employee, director, officer, trustee, beneficiary, or representative of an institutional or intermediary client of Creative Technologies.

“Creative Technologies” , “we” or “us” means Creative Technologies Limited, a company registered in the United Kingdom with office at Holmwood House Broadlands Business Campus, Langhurst Wood Road, Horsham, West Sussex, RH12 4QP. Creative Technologies is owned by the Benchmark Capital Group, which is also part of the Schroders Group.

“CT Services” , means services provided by Creative Technologies Limited.

“Creative Technologies Websites” means any website operated by Creative Technologies Limited, such as wealthplatform.com.

“Creative Technologies Mobile Application (“Mobile apps”)” means any mobile application developed and owned by Creative Technologies Limited, such as the Wealth Platform Mobile App.

“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information, which is in the possession of, or is likely to come into the possession of, Creative Technologies (or its representatives or service providers). In addition to factual information such as a name or address, it could include an expression of opinion about or an indication of intention in respect of an individual.

“You” means everyone to whom this notice is addressed, who may be:

(a) a client or prospective client of ours;

(b) a visitor of one of our websites;

(c) a user of one of our Mobile applications; or

(c) an employee, director, officer or representative of another organisation with which we have a business relationship.

(1.1) Creative Technologies generally collects and uses Personal Data of investors as a data processor, providing technology services and acting on the instructions of our clients (advisers) who. In such circumstances the advisers who invite investors to use the Wealth Platform are the data controllers of investors’ data processed through the Wealth Platform: their privacy notices describe how they use your personal data and what you can expect when we process it on their behalf. You must ensure to read those in full and contact them directly for any concern.

There are also circumstances when we act as a data controller. This means that we act independently of client instructions in processing personal data. This notice describes how we process your personal data in these circumstances.

(1.2) At Creative Technologies, we respect your privacy and we are committed to keeping your Personal Data secure.

(1.3) This Privacy Policy is directed to individuals whose personal data we process while carrying on our commercial activities. Those individuals could be clients, prospective clients or their representatives seeking financial advices, financial advisers, employees, directors, officers or representatives of another organisation with which we have a business relationship.

(2.1) Creative Technologies gathers information about you in the following ways:

(a) Information that you provide to us by using the CT Services. This includes information provided at the time of registering to use CT Services, or requesting further information or services, and when you report us a problem using the CT Services.

(b) personal details about other individuals that you enter into our systems when using our services.

(c) personal details collected by our websites through some of our cookies, unless you have denied your consent to receive those into your browser.

(3.1) Many of the products or services offered by Creative Technologies require us to obtain and process Personal Data, such as:

• Information that you provide to Creative Technologies. This includes information about you or other individuals to whom you provide services using our products. Such information may include:

• basic Personal Data such as first name; family name; email address; phone number; billing address (including city postcode and country date of birth, gender, health status, PEP status, salary and other information relating to your assets and liabilities.

By providing us with personal data, about any person on whose behalf you are acting, you agree to provide them with the information set out in this Privacy policy.

• Information that we collect or generate about you. This may include:

• Details of your visit to certain CT Services (e.g. our website), including information viewed or searched for, page response times, lengths of visit, login information, browser type and version, traffic data, location data, weblogs and other communication data, and the resources that you access, so we may compile statistics relating to your use of the CT Services
• any Personal Data that you provide during telephone and email communications with us which we may monitor and record in order to resolve complaints, improve our service and in order to comply with our legal and regulatory requirements.

(4.1) Your Personal Data may be stored and processed by us in the following ways and for the following purposes:

• to provide you with access to and the benefit of the applicable CT Services;
• to respond to any enquiries you submit to Us;
• to ensure that Content on the CT Services is presented in the most effective manner for you and for the device(s) you use to access and view the CT Services;
• to provide you with information and offers that you request from Us or which We feel may interest you;
• to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
• to administer or maintain IT systems in order to uphold standards of service;
• to operate, protect, improve and optimise the CT Services, Our business, and Our users' experience, such as to perform analytics, conduct research, personalise or otherwise customise your experience, and for advertising and marketing
• to carry out Our obligations arising from any contracts entered into between you and Us
• to allow you to participate in interactive features of the CT Services, when you choose to do so
• for ongoing review and improvement of the information provided on Creative Technologies Websites to make them user friendly and prevent potential disruptions or cyber-attacks;
• to understand feedback on Creative Technologies Products and Services and to help provide more information on the use of those products and services quickly and easily;
• to communicate with and better understand the interests of Clients and prospective Clients in order to provide services or targeted information about Creative Technologies and other Creative Technologies Products and Services;
• to effectively manage and strengthen Client and prospective Client relationships, understand Client and prospective Client needs and interests and learn more about our Clients and prospective Clients in order to develop, improve and the products and services we can offer and also to promote our products;
• for the management and administration of our business;
• in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or
• for the administration and maintenance of databases storing your Personal Data.

(4.2) When we use your Personal Data, we comply with applicable law. The law allows or requires us to use your Personal Data for a variety of reasons. These include instances where:

• we are performing our contractual obligations;
• we have legal and regulatory obligations that we have to discharge;
• we may need to do so in order to establish, exercise or defend our legal rights or those of our Clients or for the purpose of legal proceedings;
• we have obtained your consent;
• the use of your Personal Data as described is necessary for our legitimate business interests, such as:
• allowing us to effectively and efficiently manage and administer the operation of our business;
• maintaining compliance with internal policies and procedures;
• enabling quick, easy and safe access to information on Creative Technologies Products and Services.

(4.3) Your Personal Data is only accessed by authorised personnel in light of their need to access it for the purposes described in this Privacy Policy.

(5.1) We may share your Personal Data within subsidiaries of the Benchmark Capital Group and of the Schroders Group for the purposes described above.

(5.2) We may also share your Personal Data as further described below:

• with your Financial Adviser;
• with business partners of ours where they are contractually obliged to comply with appropriate data protection obligations;
• with third party agents and contractors for the purposes of them providing services both to us (for example, Creative Technologies’ accountants, professional advisors, IT and communications providers) and to Clients or prospective Clients. These third parties will be subject to appropriate data protection obligations;
• with any depository, stock exchange, clearing or settlement system, counterparties, dealers and others where disclosure of your Personal Data is reasonably intended for the purpose of effecting, managing or reporting transactions or establishing a relationship with a view to such transactions;
• where you are a joint account or portfolio holder (or otherwise one of multiple persons holding an account or portfolio), we may disclose your Personal Data to the other joint account or portfolio holder or other person;
• to the extent required by law or regulation, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators, auditors or public authorities), or to establish, exercise or defend its legal rights; and
• if we sell any part of our business or our assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes.

(6.1) Creative Technologies is a business registered in the UK and so if the Benchmark Capital Group of which is part. The personal data we process is stored in the UK, with the exception of the information processed by Google analytics in an authenticated session, which will be stored anonymously in the United States. The Schroders Group, of which the Benchmark Capital Group is a wholly owned subsidiary, is a global business with clients and operations around the world. As a result, if we share your Personal Data within companies part of the Schroders Group, it may become accessible to locations outside of your country.

(6.2) Where we transfer your Personal Data to another country, we ensure that it will be protected and transferred in a manner consistent with legal requirements. In relation to data transferred outside of the European Economic Area (the “EEA”) and the UK, for example this may be done in one of the following ways:

• the country to which we send your Personal Data is approved by the European Commission or the UK (as relevant) as offering an adequate level of protection for Personal Data, including if the recipient is established in the United States and participates in the EU-US Data Privacy Framework and its UK extension (as relevant); or
• the recipient signed up to a contract based on “model contractual clauses” approved by the European Commission or the UK (as relevant), obliging it to protect your Personal Data.

(6.3) You can obtain more details of the protection given to your Personal Data when it is transferred outside the EEA and the UK by contacting us as described in paragraph 12 below.

(7.1) Data is a critical business asset and must be protected appropriate to its risk as well as its importance or value.

We ensure safe processing operations by operating and maintaining physical, electronic and procedural safeguards to guard your non-public personal information and we restrict access only to authorised personnel. The effectiveness of these safeguards is periodically tested.

We have extensive controls and mechanisms in place designed to detect, respond and recover data and functionality in case of adverse events that may arise.

(8.1) The length of time for which we hold your Personal Data will vary as determined by the following criteria:

• the purpose for which we are using it (as further described in this Privacy Policy at paragraph 4.1) – we will need to keep the data for as long as is necessary for that purpose; and
• our legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.

(8.2) Retention periods applicable to your personal data when we process it as data controller:

• We are required to hold your personal data relating to your investments for a minimum period of 5 years and will continue to do so for so long as our regulators require.
• Any other personal data will be retained for up to 12 months following such time you cease being a user of any CT Services (e.g. you are no longer a registered user).
• If you contact Us as a prospective customer using Our e-mail address or via Our website contact form, requesting general information about our services, We will hold that personal data you choose to provide such as your name, address, e-mail address, for 12 months from our last point of contact.
• If you contact Us as a prospective customer using Our e-mail address or via Our website contact form, requesting quotes and information about Our services in respect of specific projects, We will hold that personal data you choose to provide such as your name, address, e-mail address, for 12 months from Our last point of contact.
• Data such as IP addresses, traffic data, location data, weblogs and other communication data will be retained for 12 months.

(9.1) In all the cases in which we collect, use or store your Personal Data as data controller, you may have the following rights:

• the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
• the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain your Personal Data to comply with a legal or regulatory obligation or to satisfy our internal audit requirements;
• in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit such data to a third party where this is technically feasible. Please note that this right only applies to Personal Data that you have provided directly to Creative Technologies;
• the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
• the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are required or entitled to retain it;
• the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are required or entitled to refuse that request; and
• the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

(9.2) You can exercise your rights by contacting us using the details provided at paragraph 12 below. For personal information controlled by your advisers, you will need to contact them directly as described in their privacy notice.

(10.1) If you use a Creative Technologies Website, we do not collect information about your usage through cookies, unless you engage into an authenticated session by clicking the “log-in” button on the upper right side of the screen, using the credentials we provided you.

During your authenticated, secure session needed for using the Wealth Platform application, the type of information collected is explained in our dedicated Cookie Notice. As detailed in such notice, we provide you with the opportunity to selectively accept/reject certain categories of cookies in your Web browser through our Cookie Manager Application. If you accept cookies of the tracking category, we will be able to combine the information we collect about your usage of the Wealth Platform application with other information we may know about you, such as any searches you conduct on other Web Sites of the Schroders group or information you provided to us to inquire about our services or to obtain support. We will use this combined information to improve the functionality and usability of the Wealth Platform and to better understand your interest for other products and services that we offer.

(10.2) If you use a Creative Technologies Website and follow a link from it to another website (including a website operated by Creative Technologies), different privacy policies may apply. Prior to submitting any Personal Data to a website, you should read the privacy policy applicable to that website.

(11.1) Any changes we make to our Privacy Policy in the future will be posted on this website and where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.

(12.1) If you have any questions or concerns about Creative Technologies’ handling of your Personal Data, or about this Privacy Policy, or to exercise any of your rights, please contact us at the address below.

To exercise your right to withdraw consent to receive electronic marketing communications at any time, please follow “unsubscribe” instructions found in such marketing materials.