Privacy and Cookies

We (Equiniti Limited and Equiniti Financial Services Limited) may keep the personal details that you or others give us during your relationship with us on an Equiniti database. These details may include:

• information that you or your agents give us on application forms, in letters, via electronic messages or over the phone
• what we know from providing you with any services and analysing any transactions you carry out through us
• information that comes to us from credit reference and fraud detection agencies or services, and registration or stockbroking industry exchanges
• information we receive from our client companies or their agents.

We may store, use and process your personal information in order to:

• assess any application you make to participate in any service we provide
• provide you with services
• identify other products and services that might be suitable for you
• keep our records about you up to date
• check your identity
• prevent and detect fraud and/or money laundering
• recover debts, and
• carry out research and statistical analysis about our services and how we might improve them. Sometimes we may use an outside market research agency to do this for us, in which case we undertake to ensure that they appropriately protect any personal customer data we share with them.

Unless you tell us not to, we may share your information within the Equiniti group and we or they may contact you by email (where this is permitted) or post about:

• Equiniti group products and services we believe may interest you. Our group includes all companies with the Equiniti name and associated companies
• selected products and services from third party businesses we know and trust.

Under the Data Protection Act 1998 you are entitled to a copy of the information we hold about you on request, on payment of a fee. If you think any information we hold about you is inaccurate, don’t hesitate to let us know so that we can correct it.

The information we hold about you is confidential. We will only ever disclose it outside the Equiniti group:

• at your request or with your consent
• in line with what we have explained above
• if the law requires or permits disclosure or there is a duty to the public to reveal it
• if we are asked to do so by the Financial Conduct Authority, the London Stock Exchange or any other relevant regulatory authority or exchange in the UK or overseas
• to investigate or prevent fraud or other crimes
• to our client company or companies for whom we act as registrar (directly or indirectly)
• to our agents and others in connection with running accounts and other services for you
• to any individual or company to whom we propose to transfer our business or any part of it
• if we cease to act as registrar for one of the companies in which you hold shares and we are asked by that company to provide them with your email address so that they (or their agent) can contact you about the provision of an equivalent service by the new registrar appointed by them. Your email address will only be used for this purpose and appropriate safeguards will be put in place to protect your personal data.

We may administer accounts and provide you with some services via agencies in countries outside Europe, including Jersey and other countries such as India or the USA, where data protection laws and standards differ from those in the UK. But even if we are processing your personal details outside Europe

• there will always be a contract in place to ensure that such information is appropriately protected, and
• we will continue to be strictly bound by the UK’s Data Protection Act 1988.

Like many websites, this service uses cookies. Cookies are small text files of information that a web server transfers to a cookie file on the device you are using to browse this website (commonly a computer or mobile phone) to collect and store information. It is important for us to use them because we can deliver an efficient service to you and also analyse customer journeys through the website to inform future enhancements.

Likewise, cookies are beneficial to your use of this website because they avoid the need for you to enter the same information several times during one transaction and also safeguard your security when using our secure online services.

There a two types of cookie which can be stored on your device:

• a session cookie which lasts for the amount of time you keep your web browser open for, and;
• a persistent cookie which is stored on your device for a defined period of time.

We use both of these types of cookies which fall into two categories termed by us as (1) strictly necessary cookies, and (2) performance analytics cookies.

These are the types of cookies that let you move around the website and use its features.

In this category we use both session and persistent cookies. The session cookies help you make applications for services and also login and navigate around secure areas of the website. The persistent cookie is only set if you tick a box on the login screen for the website to remember part of your login details for a future visit. However, it will make you aware that a cookie is used to support this and also advise you not to do this if you are using a computer in a public place.

We use performance analytics cookies to gather statistical information on how people navigate the site such as: the number of visits and number of pages per visit, paths taken by visitors through the site, duration and time of visits, type of web browsers used and other general data. From this detail, we are able to continuously improve our visitors’ experience of this website.

We use Google Analytics to provide this information. This sets both session and persistent cookies to help us understand user behaviour. The session cookies (_utmb and _utmc) tell us when a user enters the website and either exits it or performs no further actions for longer than 30 minutes. The persistent cookies (_utma and _utmz) tell us how visitors find our website and their uniqueness i.e. their number of visits and how recent or frequent they are.

None of the cookies used on our websites collect personally identifiable information about you.

By continuing to use this website, you are consenting to us placing cookies on your device for the purposes detailed above.

If you do not want cookies placed on your device, you can find details of how to block them on the most widely used devices and browsers at allaboutcookies.org. Please note though that by blocking our cookies, we cannot guarantee that the website and your experience whilst visiting are as we intended it to be.

You can also block all Google Analytics cookies across all websites by getting the Google Analytics Opt-out Browser Add-on here.

We continue to monitor the situation regarding clarity of the new EU cookies directive and steps required to implement these on a practical level. We will make any further necessary adjustments to this website as further guidance is issued by the Information Commissioner’s Office.

We monitor and record some phone calls in case we need to check we have carried out your instructions correctly, to help maintain our quality standards and for security purposes.

To the extent that personal data is processed about you, we will employ appropriate security measures given the nature of that data. However, you recognise that your use of the Internet (and our website) is entirely at your own risk. However, we have no responsibility or liability for the security of personal information transmitted via the Internet.

Our website may provide links and banner advertisements to third party sites. Please note that we are not responsible for, and have no control over, information that is submitted to or collected by these third parties. Since we do not control those websites, you are responsible for reviewing and abiding by the privacy policies of these third-party sites.

We may check what you have told us and share that information with fraud prevention agencies. It is important that you give us accurate information. If you give us false or inaccurate data and we suspect fraud we will record this at the fraud prevention agencies.

If you feel your privacy has been breached by us, then please write to:

Equiniti
Aspect House
Spencer Road
Lancing
West Sussex
BN99 6DA

You must not use any computers, computer equipment, network resources or any services provided by us for any illegal purpose, or for accessing, receiving or transmitting any material deemed illegal, indecent, offensive or otherwise unacceptable under UK law.

All passwords and usernames allocated to you must be kept secret and must not be disclosed to anyone without our prior written authorisation.

You must not use any false identity in email or other network communications.
You must not attempt or participate in the unauthorised entry or viewing of another user's account or into another system.

You must not use the services and/or network systems or any part thereof for fraudulent activities, or to breach another organisation's security (cross-network hacking). This is an illegal act and prosecution under criminal law may result.

Please note that this policy will be reviewed and may be changed from time to time. The revised policy will be posted to this page (so that you are always aware of the information we collect, how we use it and under what circumstances we disclose it).

Any decision made by us in relation to the services provided to you shall be final.