Privacy Policy

Gresham Technologies
Updated: September 2024

Introduction

The Gresham Group (as defined below) provides software and service specialising in providing solutions for data management, integrity and control, banking integration, payments and cash management. As an essential part of our business, we collect and manage data relating to our customer, visitors (to our website or to our premises) and other contacts.

Gresham respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or when you visit our premises and tell you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Gresham collects and processes your personal data through you visiting our premises, your use of this website, including any data you may provide through this website if you wish to consent to updates, gain access to specific content, submit an enquiry, submit a support ticket for one of our solutions, or ask us to contact you. You may also correspond with us by email, telephone or other means, or in person, as a result of which we may collect your information.

This website is not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

The Gresham group is made up of a number of legal entities, details of which are set out in Schedule 1 of this policy (the “Gresham Group”, “Group” or “Gresham”). This privacy policy is issued on behalf of the Gresham Group so when we mention Gresham, "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the Gresham Group that acts as the Controller of your Personal Data. For the avoidance of doubt, this privacy policy does not apply to the extent we process Personal Data in the role of a processor on behalf of our customers. 
 

Gresham’s in-house Data Protection team are responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Data Protection team using the details set out below.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes name, job title, username or similar identifier.
• Contact Data includes company address, email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, your login data, geographic location, type and language and time zone setting, and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• CCTV and physical security CCTV systems are installed in some of our premises. These collect images and videos of certain entrances or exits of our premises and of certain secure areas of or equipment at our offices, and other information relating to access of our premises obtained through electronic means, such as swipe card records, or visitor logbook. If you attend our premises in person, we may also collect practical details such as arrival time, departure time and car registration details (if relevant).

We operate a separate, employment-related data protection policy which sets out the information, use and other details regarding our processing activities for employee and job applicant data. A copy of this policy is made available to all employees and job applicants upon request.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences other than as require for employment and recruitment purposes and which is therefore covered under our separate employment data protection policy.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact information by corresponding with us by post, phone, email, completing a form on our website, or otherwise. This includes personal data you provide when you:
  • request information relating to our products and services;
  • submit a customer support service ticket;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • give us feedback or contact us: or
  • if you attend our premises in person, we may also collect practical details such as arrival time, departure time and car registration details (if relevant).
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

Technical Data from the following parties:

• (a)    analytics providers such as Microsoft, HubSpot and Google Analytics based outside the UK; and
• (b)    advertising networks and search information providers such as LinkedIn and Google Advertisement based inside and outside the UK

Please see our Cookie Policy for further information: https://www.greshamtech.com/cookie-policy

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• to provide products and services to our customer (your employer);
• to provide you with information regarding our products and services and other marketing communications or news or invitations that may be of interest to you or your organisation;
• to contact you for your views or a survey as part of market research;
• to manage and ensure the security of our premises;
• generally, to administer our relationship with you and respond to your queries or feedback;
• generally, to administer, improve and develop our business.
• generally, to comply with our statutory and regulatory obligations; and
• generally, to enforce our legal rights.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

5. Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

6. Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased a solution or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

7. Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

8. Disclosures of your personal data

We may share your information to any member of the Gresham Group insofar as reasonably necessary for the purposes, and on the legal basis, set out in this policy.

We use both internal computer systems and third-party computer systems to hold information that you provide or that we collect. Our internal computer systems are in the United Kingdom (“UK”) and elsewhere including inside and outside of the European Economic Area (“EEA”). The third-party systems that we use include cloud- based IT platforms and providers of support or specialist products/services that may be based and/or process and/or store information in the UK or elsewhere including inside and outside of the EEA. Both our internal systems and our third-party computer systems are access controlled such that only our authorised personnel are able to access the information. Our authorised personnel may be based in any of our global locations.

We may share your information with our insurers and professional advisers or other service providers insofar as reasonably necessary for the purposes of insurances, risk management, professional advice and operational necessity.

In addition to the third-party systems referred to above, we engage suppliers and/or subcontractors from time to time to assist us with our business processes and practices, which may include providers of human resources services, marketing consultants, IT consultants. We may share your information with any of these suppliers and/or subcontractors as reasonably necessary for the purposes and on the legal basis set out above.

We may also be obliged to disclose information under certain laws or by order of court or other competent regulatory body or may be permitted to disclose it under applicable data protection laws.

9. International transfers

We share your personal data within the Gresham Group and where applicable to our third-party suppliers or subcontractors. This may involve transferring your data outside the UK and EEA.

Whenever we transfer your personal data out of the UK and EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• For transfers outside of the UK and EEA but within the Gresham Group we have Intra Group Transfer Agreements in place.
• For transfers outside of the UK and EEA but not within the Gresham Group, we will only transfer your personal data:
  • to countries that have been deemed to provide an adequate level of protection for personal data.
  • Where we have in place specific contracts approved for use in the UK and EEA which give personal data the same protection it has in the UK or EEA (as the case may be).

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA (as the case may be).

As you may be aware, data protection laws vary from country to country. Our transfer of personal data to other countries outside of the UK and EEA could result in your personal data being available to governments and/or other Supervisory Authorities under the local law.

Electra Information Systems Inc (“Electra”) and Gresham Technologies (US) Inc (“Gresham US”), are registered and comply with the EU-U.S. Data Privacy Framework, the Swiss – US Data Privacy Framework and the UK extension to the EU-US Data Privacy Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (“EU”), Switzerland and the UK to the United States. For further information of the Data Privacy Framework please see Schedule 2.

10. Data security

We have put in place appropriate organisational and security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers including Contact, Identity, Financial and Transaction Data for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

12. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

If you wish to exercise any of your rights under data protection laws that require us to take an action, please contact us at dataprotection@greshamtech.com.

We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

13. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience that we can reasonably manage. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other entities in the Gresham Group act as joint controllers or processors and are based in Australia, Canada, India, Luxembourg, Malaysia, Singapore and the United States and provide operational services (such as central IT, HR, finance and legal services for the Gresham Group), as well as services to our customers.

External Third Parties

• Service providers based in the UK, EEA, India, and United States including IT and system administration services.
• Professional advisers including auditors and insurers based in UK, EEA and the United States who provide consultancy, banking, legal, insurance and accounting services.

14. Your legal rights

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you (for example right of erasure does not apply to data subjects in Australia, if applicable, at the time of your request).

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer/data portability of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine- readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

15. Supplemental Information

Supplemental Information for Australia:

This Supplement forms part of the Gresham’s privacy policy for any personal information collected, held or disclosed by the Gresham Group.

In this Supplement, “personal information” has the meaning given to it in the Privacy Act 1988 (Cth) (“Privacy Act”). Accordingly, in this Supplement, “personal information” is any “information or opinion about an identified individual or an individual who is reasonably identifiable, regardless of whether the information or opinion is true or not”.

For the purposes of this Supplement, we may collect certain personal information about you in connection with your interactions with us, where such personal information includes the information set out in section 2 in this privacy policy.

We may collect personal information about you from a number of sources and in a number of ways, as outlined in section 3 of this privacy policy. Regardless of the method that we use to collect personal information about you, we only collect personal information through lawful and fair means, in accordance with the Privacy Act.

Where it is lawful and reasonable for you to do so, you have the right to deal with us on an anonymous or pseudonymous basis. As permitted by law, and subject to the following, we will give you the option of not identifying yourself, or of using a pseudonym, in dealing with us. However, if you choose to interact with us on such a basis, or you do not provide us with personal information when we request it, then we may be unable to provide our products or services when you request that we do so.

Further, we reserve the right to verify your identity in certain circumstances. For example, we may need to verify your identity in order to assist us to fulfill our obligations owed to you when we enter into a contract with you regarding any of our products or services. Additionally, when you request access to or correction of any personal information we hold about you, or when you wish to make a complaint about how we have handled your personal information, we reserve the right to verify your identity and contact details in order to facilitate our handling and satisfaction of your access or correction request, or to investigate and deal with your complaint.

Under the Privacy Act, we are only permitted to collect personal information to the extent reasonably necessary to achieve the purposes for which the information is to be collected. The purposes for which we collect, use and disclose personal information about you when you are located in Australia are as outlined in section 5 above.

Where we undertake activities in Australia, or if you are located in Australia, we are regulated by the Privacy Act, the Australian Privacy Principles and other applicable laws and codes in relation to your personal information. In this document, the term “personal data” includes personal information under the Privacy Act. For further information on Gresham’s compliance with The Privacy Act please contact Gresham’s Data Protection team at dataprotection@greshamtech.com.

If you are based within Australia, please note that where it is necessary in the provision of products and services to you, we may transfer your personal data to Gresham entities located in countries outside Australia, including Gresham entities in the UK, the EEA and the United States. You consent to any such overseas disclosure and acknowledge that APP 8.1 will not apply to such disclosure.

We retain your personal information only for as long as it is reasonably necessary for us to retain the information to fulfil the purpose(s) of collection, subject to applicable laws relating to the retention of information and documents. When the information is no longer required for the purpose(s) for which we have collected the information, then (unless otherwise required or authorised by law) we will take reasonable steps to de-identify or destroy the personal information that is no longer required.

While we hold your personal information, we take reasonable steps to protect your personal information from unauthorised access, use or disclosure.

You may make a complaint directly to us if you are unhappy with how we have collected, held, used or disclosed your personal data, if you are unhappy with our response to your complaint and any suggested resolution, you may then contact the Office of the Australian Information Commissioner (“OAIC”) and lodge a complaint via the process detailed on the OAIC’s website (www.oaic.gov.au).

Supplemental information for California:

The California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”) applies to the handling of Personal Data for individuals and households residing in California. Personal data processed by the Gresham Group for individuals residing in California is collected and processed by the Gresham Group in accordance with the CCPA and CPRA. The following information in this CCPA and CPRA supplement applies to California residents only and addresses personal information we collect online and offline. This Supplement does not apply to Gresham Group personnel. Sections 2-5 of this Supplement do not apply to job applicants.

This Supplement uses certain terms that have the meaning given to them in the CCPA, CPRA and their implementing regulations.

1. Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the effective date of this Supplement) the following categories of personal information about you:

• Identifiers: identifiers such as name, user name and similar identifier, telephone number, online identifier, internet protocol address, email address, account name.
• Commercial Information: commercial information, including records of services and support tickets.
• Online Activity: Internet and other electronic network activity information, including information regarding your interaction with our website.

We may use (and may have used during the 12-month period prior to the effective date of this Supplement) your personal information for the purposes described in this privacy policy and for the following business purposes specified in the CCPA:

• Performing services, including providing customer support services, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services.
• Auditing related to a current interaction with you and concurrent transactions and auditing compliance.
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity.
• Debugging to identify and repair errors that impair existing intended functionality.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

Managing career opportunities with Gresham Group.

2. Sources of Personal Information

During the 12-month period prior to the effective date of this Supplement, we may have obtained personal information about you from the following categories of sources:

• Directly from you, such as when you contact us with a question or comment
• From your devices, such as when you visit our website
• Suppliers who provide services on our behalf
• Third parties or publicly available sources

3. Sale of Personal Information

We do not and will not sell your personal information.

4. Sharing of Personal Information

During the 12-month period prior to the effective date of this Supplement, we may have shared your personal information with certain categories of third parties, as described below.

We may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

5. California Consumer Privacy Rights

You have certain choices regarding our use and disclosure of your personal information, as described below.

Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed, and sold about you during the past 12 months.

Deletion: You have the right to request that we delete certain personal information we have collected from you.

How to Submit a Request: To submit an access or deletion request (or to submit a request as an authorized agent on behalf of a consumer), email us at dataprotection@greshamtech.com or call us at +44 (0) 207 653 0222. For questions or concerns about our privacy policies and practices, please email us at dataprotection@greshamtech.com or call us at +44 (0) 207 653 0222.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to or deletion of your personal information, we may require you to provide any of the following information: your email address, the name of the Gresham Group representative with whom you typically interact, if any, and the date of your last interaction with a Gresham Group representative, if applicable. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Additional Information: If you choose to exercise any of your rights under the CCPA and/or CPRA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

Supplemental Information for Canada:

The Personal Information Protection and Electronic Documents Act (“PIPEDA”) and relevant provincial laws, in particular Quebec’s Bill (64) applies to the handling of Personal Data in Canada. Personal Data processed by the Gresham Group is collected and processed in accordance with PIPEDA and the relevant provincial laws. For further information on Gresham’s compliance with PIPEDA and the relevant provincial laws please contact Gresham’s Data Protection team.

Supplemental information for Malaysia:

The Personal Data Protection Act 2010 (“PDPA Malaysia”) applies to the handling of Personal Information Malaysia (regardless of whether or not the Personal Data is processed in the context of the establishment or not established in Malaysia, but equipment is used to process the Personal Data otherwise than for the purpose of transit through Malaysia). Personal data processed by the Gresham Group is collected and processed in accordance with PDPA Malaysia. For further information on Gresham’s compliance with PDPA Malaysia please contact Gresham’s Data Protection team.

Supplemental Information for Singapore:

The Personal Data Protection Act 2012 as amended (“PDPA”), applies to the handling of Personal Data in Singapore. Personal Data processed by the Gresham Group is collected and processed in accordance with PDPA. For further information on Gresham’s compliance with PDPA please contact Gresham’s Data Protection team or contact Gresham’s Singapore Data Protection Officer registered with the Singapore Personal Data Protection Commission. 

Contact details 
dyates@greshamtech.com. 
44 (0) 207 653 0222 or Singapore office number +65 6932 2683.

We do not we sell any Personal Data collected.

16. How to contact us

Full name of legal entity: Gresham Technologies Limited

Email address: dataprotection@greshamtech.com

Postal address: Aldermary House, 10-15 Queen Street, London, EC4N 1TX

Although our aim is to ensure that we handle any issues or complaints quickly and efficiently, you have the right to make a complaint at any time to your local data protection authority. The Information Commissioner's Office (ICO), is the UK regulator for data protection issues (www.ico.org.uk). In the EEA the local data protection authorities information can be found on the European Data Protection Board website (https://www.edpb.europa.eu/edpb.en).

17. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. Historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

SCHEDULE 1

Gresham Companies

SCHEDULE 2

EU – US Data Privacy Framework

Swiss – US Data Privacy Framework

UK Extension to the EU -US Data Privacy Framework

(collectively “Data Privacy Framework”)

Electra and Gresham US comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Electra and Gresham US have certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Electra and Gresham US have certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/

In the context of an onward transfer, Electra and Gresham US have responsibility for the processing of personal information it receives under the Data Privacy Framework and subsequently transfers to a third party acting as an agent on its behalf. Electra and Gresham US shall remain liable under the Data Privacy Framework if its agent processes such personal information in a manner inconsistent with the Data Privacy Framework, unless the organisation proves that it is not responsible for the event giving rise to the damage.

In compliance with the Data Privacy Framework, Electra, and Gresham US commit to resolve complaints about collection or use of your personal information. EU, Swiss and UK individuals with inquiries or complaints regarding our Data Privacy Framework policy should first contact our Data Protection team at: dataprotection@greshamtech.com.

Electra and Gresham US have further committed to refer unresolved Data Privacy Framework complaints to JAMS Data Privacy Framework Program, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/dpf-dispute-resolution. The services of JAMS are provided at no cost to you.

Under the Privacy Framework, Electra and Gresham US are subject to the investigatory and enforcement power of the Federal Trade Commission (FTC), which has Data Privacy Framework investigatory and enforcement powers over Electra and Gresham US. Under certain circumstances, individuals may be able to invoke binding arbitration to address complaints about Electra’s or Gresham US’ compliance with the Data Privacy Framework Principles.