Ashurst is committed to protecting your privacy. This privacy notice ("Notice") explains how we collect and use your personal data and which rights and options you have in this respect. If you would like to learn more about our client confidentiality obligations, please refer to our terms of engagement. Please also refer to our Cookie Policy [https://www.ashurst.com/en/cookies/] which explains the use of cookies and other web tracking devices via this website ("Website").

• Who is responsible for your personal data?

Ashurst is responsible for your personal data. Ashurst comprises Ashurst LLP ("we", "us" or "our") (OC330252) London Fruit & Wool Exchange, 1 Duval Square, London E1 6PW, United Kingdom; Ashurst Australia, (ABN 75 304 286 095) a general partnership constituted under the laws of Australian Capital Territory at 5 Martin Place, Sydney, New South Wales 2000 and their respective representatives and affiliates throughout the world (the "Ashurst Entities"). Specifically, your data will be controlled by the Ashurst Entity that you have instructed or that is providing services or communication to you in your region.

• Which personal data do we collect?

The personal data we collect may include:

• Contact information, such as your name, job title, postal address, including your home address or other personal information, where you have provided this to us, business address, telephone number, mobile phone number, fax number and email address and other details of your business;
• Payment data, such as data necessary for processing payments and fraud prevention, including credit/debit card numbers, security code numbers and other related billing information;
• Further business information necessarily processed in a project or client contractual relationship with Ashurst or voluntarily provided by you, such as instructions given, payments made, requests and projects;
• Your password (if any) for this Website or other password protected platforms or services, where you have one;
• Information collected from publicly available resources, integrity data bases and credit agencies;
• If legally required for compliance purposes, information about relevant and significant litigation or other legal proceedings against you or a third party related to you and interaction with you which may be relevant for antitrust purposes;
• Special categories of personal data. In connection with the registration for and provision of access to the FinTech Legal Labs or an event or seminar, we may ask for information about your health for the purpose of identifying and being considerate of any disabilities or special dietary requirements you may have. Any use of such information is based on your consent. If you do not provide any such information about disabilities or special dietary requirements, we will not be able to take any respective precautions;
• Other personal data regarding your preferences where it is relevant to legal services that we provide; and/or
• Details of your visits to our premises.

From time to time, it may include personal data about your membership of a professional or trade association or union, health personal data, details of dietary preferences when relevant to events to which we invite you and details of any criminal record you may have.

• How do we collect your personal data?

We may collect personal data about you in a number of circumstances, including:

• When you or your organisation make an online application, over the phone or via any other medium for the FinTech Legal Labs;
• When you or your organisation seek legal advice from us or use any online client services;
• When you or your organisation browse, make an enquiry or otherwise interact on this Website or through the email address or phone number provided on our Website (and for such purpose you may be providing information such as your name, email address and telephone number so as to allow us to get back to you for your questions and comments);
• When we record images of you via CCTV on our premises;
• When you attend a seminar or another FinTech Legal Labs event or sign up to receive personal data from us, including training; or
• When you or your organisation offer to provide or provide services to us.

In some circumstances, we collect personal data about you from a third party source. For example, we may collect personal data from your organisation, other organisations with whom you have dealings, government agencies, a credit reporting agency, an information or service provider or from a publicly available record.

• Are you required to provide personal data?

As a general principle, you will provide us with your personal data entirely voluntarily; there are generally no detrimental effects for you if you choose not to consent or to provide personal data. However, there are circumstances in which Ashurst cannot take action without certain of your personal data, for example because this personal data is required to process your instructions or orders, provide you with access to a web offering or newsletter or to carry out a legally required compliance screening. In these cases, it will unfortunately not be possible for us to provide you with what you request without the relevant personal data and we will notify you accordingly.

• For which purposes will we use your personal data?

You agree that we may use your personal data and any information you provide in accordance with this Notice for the following purposes only ("Permitted Purposes"):

• Providing legal advice or other services or things you may have requested, including online or legal technology services or solutions as instructed or requested by you or your organisation;
• Managing and administering your or your organisation's business relationship with us, including processing payments, accounting, auditing, billing and collection, support services;
• Compliance with our legal obligations (such as record keeping obligations), compliance screening or recording obligations (e.g. under antitrust laws, export laws, trade sanction and embargo laws, for anti-money laundering, financial and credit check and fraud and crime prevention and detection purposes), which may include automated checks of your contact data or other information you provide about your identity against applicable sanctioned-party lists and contacting you to confirm your identity in case of a potential match or recording interaction with you which may be relevant for compliance purposes;
• To analyse and improve our services and communications to you, and to communicate with you about other topics that we believe may be of interest to you, subject to obtaining your consent in accordance with applicable law, if required;
• Protecting the security of and managing access to our premises, IT and communication systems, online platforms, websites and other systems, preventing and detecting security threats, fraud or other criminal or malicious activities;
• For insurance purposes;
• For our business marketing purposes;
• For monitoring and assessing compliance with our policies and standards;
• For health and safety purposes;
• To identify persons authorised to trade on behalf of our clients, customers, suppliers and/or service providers;
• To comply with our legal and regulatory obligations and requests anywhere in the world, including reporting to and/or being audited by national and international regulatory bodies;
• To comply with court orders and exercises and/or defend our legal rights;
• For the evaluation of our performance and for an improvement in our future services and/or events, if you have kindly provided us with any feedback; and
• For any purpose related and/or ancillary to any of the above or any other purpose for which your personal data was provided to us.

Where you have expressly given us your consent, we may process your personal data also for the following purposes:

• Communicating with you through the channels you have approved to keep you up to date on the latest legal developments, announcements, and other information about Ashurst and FinTech Legal Labs services, products and technologies (including client briefings, newsletters and other information) as well as events and projects;
• Customer surveys, marketing campaigns, market analysis, sweepstakes, contests or other promotional activities or events; or
• Collecting information about your preferences to create a user profile to personalise and foster the quality of our communication and interaction with you (for example, by way of newsletter tracking or website analytics).

With regard to marketing-related communication, we will - where legally required - only provide you with such information after you have opted in and provide you the opportunity to opt out anytime if you do not want to receive further marketing-related communication from us. We will not use your personal data for taking any automated decisions affecting you or creating profiles other than described above.

Depending on for which of the above Permitted Purposes we use your personal data, we may process your personal data on one or more of the following legal grounds:

• Because processing is necessary for the performance of a client instruction or other contract with you or your organisation;
• To comply with our legal obligations (e.g. to keep pension records or records for tax purposes); or
• Because processing is necessary for purposes of our legitimate interest or those of any third party recipients that receive your personal data, provided that such interests are not overridden by your interests or fundamental rights and freedoms.

In addition, the processing may be based on your consent where you have expressly given that to us.

• With whom will we share your personal data?

We may share your personal data in the following circumstances:

• We may share your personal data between the Ashurst Entities throughout the world or our affiliates and with other partner organisations of FinTech Legal Labs on a confidential basis where required for the purpose of providing legal advice or other products or services and for administrative, billing and other business purposes. A list of the countries in which Ashurst Entities are located can be found on the Ashurst website;
• If you are a client of Ashurst, or are contracted to or are an agent of a client of Ashurst, we may disclose your personal data to:
- Barristers, other legal specialists (including mediators), consultants or experts engaged in your matter; or
- Foreign law firms for the purpose of obtaining foreign legal advice;

• If we have collected your personal data in the course of providing legal services to any of our clients, we may disclose it to that client, and where permitted by law to others for the purpose of providing those services;
• We may disclose your information on a confidential basis to third parties for the purposes of collecting your feedback on the firm’s service provision, to help us measure our performance and to improve and promote our services;
• We may share your personal data with companies providing services for money laundering checks, credit risk reduction and other fraud and crime prevention purposes and companies providing similar services, including financial institutions, credit reference agencies and regulatory bodies with whom such personal data is shared;
• We may share your personal data with any third party to whom we assign or novate any of our rights or obligations;
• We may share your personal data with courts, law enforcement authorities, regulators or attorneys or other parties where it is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process;
• We may also instruct service providers within or outside of Ashurst, domestically or abroad, e.g. shared service centres, to process personal data for the Permitted Purposes on our behalf and in accordance with our instructions only. Ashurst will retain control over and will remain fully responsible for your personal data and will use appropriate safeguards as required by applicable law to ensure the integrity and security of your personal data when engaging such service providers;
• We may also use aggregated personal data and statistics for the purpose of monitoring website usage in order to help us develop this Website and our services; and
• We may also transfer your personal data to third parties as a result of, or in connection with a sale, merger, consolidation, change in control, transfer of assets, bankruptcy, reorganisation, or liquidation of Ashurst Entities or the FinTech Legal Labs programme. We retain the right to transfer or assign all information in such circumstances. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal data you have provided through this website in a manner that is consistent with this Notice.

Otherwise, we will only disclose your personal data (i) when you direct us or give us permission, (ii) when we are required by applicable law or regulations or judicial or official request to do so, (iii) as required to investigate actual or suspected fraudulent or criminal activities or when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of such activities, (iv) to enforce the terms of this Notice, (v) to protect the rights, property, security or safety of FinTech Legal Labs, its sponsors and the supporting organisations to the FinTech Legal Labs, Website users or the public, (vi) to respond to an emergency, or (vii) as otherwise stated in this Notice.

• Personal data about other people which you provide to us

If you provide personal data to us about someone else (such as one of your directors or employees, or someone with whom you have business dealings) you must ensure that you are entitled to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Notice. In particular, you must ensure the individual concerned is aware of the various matters detailed in this Notice, as those matters relate to that individual, including our identity, how to contact us, our purposes of collection, our personal data disclosure practices (including disclosure to overseas recipients), the individual's right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences if the personal data is not provided (such as our inability to provide services).

• Keeping personal data about you secure

We will take appropriate technical and organisational measures to keep your personal data confidential and secure in accordance with our internal procedures covering the storage, disclosure of and access to personal data. Personal data may be kept on our personal data technology systems, those of our contractors or in paper files.

Kindly note, however, that maintaining “perfect security” on the internet is not possible and we cannot guarantee the full security of your information. We shall not be liable for any system violations or interception of our transmission. Any liability associated with any claim relating to a breach of security, data or information is hereby fully disclaimed, to the fullest extent provided under law.

• Transferring your personal data abroad

Ashurst is a globally active law firm. We may transfer your personal data abroad if required for the Permitted Purposes as described above. This may include countries which do not provide the same level of protection as the laws of your home country (for example, the laws within the United Kingdom and other countries in the European Economic Area, or Australia). We will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by the General Data Protection Regulation (EU) 2016/679 or other relevant laws. This includes entering into the EU Standard Contractual Clauses which are available here [https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en]. You may contact us anytime using the contact details below if you would like further information on such safeguards.

All Ashurst offices throughout the world will at all times ensure a level of data protection at least as protective as that required in the United Kingdom and other countries in the European Economic Area and Australia. We will also require our agents, consultants and sub-contractors and others who are outside the United Kingdom, the European Economic Area or Australia and to whom we transfer your personal data to ensure a similar level of data protection.

When doing so we will comply with applicable data protection requirements and take appropriate safeguards to ensure the security and integrity of your personal data,

• Updating personal data about you

If any of the personal data that you have provided to us changes, for example if you change your email address or if you wish to cancel any request you have made of us, or if you become aware we have any inaccurate personal data about you, please let us know by sending an email to fintechlegallabs@ashurst.com. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete Personal Data that you provide to us.

• For how long do we retain your personal data?

Your personal data will be deleted when it is no longer reasonably required for the Permitted Purposes or you withdraw your consent (where applicable) and we are not legally required or otherwise permitted to continue storing such data. We will, in particular, retain your personal data where required for Ashurst/FinTech Legal Labs to assert or defend against legal claims until the end of the relevant retention period or until the claims in question have been settled.

• Your rights

Subject to certain legal conditions, you have the right to request a copy of the personal data about you which we hold, to have any inaccurate personal data corrected and to object to or restrict our using your personal data. You may also make a complaint if you have a concern about our handling of your personal data.

If you wish to do any of the above please send an email to fintechlegallabs@ashurst.com. We may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorised disclosure of data. We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your data, and for any additional copies of the personal data you request from us.

We will consider any requests or complaints which we receive and provide you with a response in a timely manner. If you are not satisfied with our response, you may take your complaint to the relevant privacy regulator. We will provide you with details of your relevant regulator upon request.

• Links to Other Sites

Occasionally we provide links to other websites for your convenience and information. These websites operate independently from our Website and are not under our control. These sites may have their own privacy policies or terms of use, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of these sites, any products or services that may be offered through these sites, or any other use of the linked sites.

• Updates to this Notice

This Notice was last updated in October 2019. We reserve the right to update and change this Notice from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. In case of any such changes, we will post the changed Notice on this Website or publish it otherwise. The changes will take effect as soon as they are posted on this Website.

• How to get in touch with Ashurst

We welcome your questions or views about this Website and our Notice. If you would like to contact us with any queries or comments, please send an email to fintechlegallabs@ashurst.com or send a letter to Data Manager, Ashurst LLP, London Fruit & Wool Exchange, 1 Duval Square, London E1 6PW, United Kingdom, or to the Privacy Officer, Ashurst Australia, GPO Box 9938 Sydney, New South Wales, Australia 2001.

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