Privacy Policy

This Privacy Policy relates to Instinctif Partners Holdings Limited (and / or any Group
Company), a company registered in England and Wales under number 07780133, whose
registered office is at 65 Gresham Street, London EC2V 7NQ (“the Company”), and is
addressed to all individuals outside our organisation with whom we interact, including,
clients, suppliers, visitors to our website including any of its landing pages and other sites
operated by us (our “sites”), employees and other recipients of our services (herein referred
to “you”).

For the purposes of this document, “Group Company” or the “Company” means the
Company and any holding company or any parent company or any subsidiary or fellow
subsidiary undertaking of the Company or such companies, as such terms are defined in
s1159, s1162 (together with Schedule 7 and the definition of "parent company" in s1173),
s1161 and Schedule 6 of the Companies Act 2006, and "Group Company" means any of
them.

Our privacy policy explains how we collect, use, share and protect your personal
information. If we update this policy, we’ll post any changes on our website.

We use your data to provide and improve our services. By visiting this site and using our
services, you agree to the collection and use of information in accordance with this policy.

We have appointed IT Governance Europe Limited to act as our EU representative. If you

wish to exercise your rights under the EU General Data Protection Regulation (EU GDPR),
or have any queries in relation to your rights or general privacy matters, please email our
Representative at [email protected].

Please ensure to include reference to Instinctif Partners in any correspondence you send to our
representative.

Definitions
Personal Data” means data about a living individual who can be identified from those data
(or from those and other information either in our possession or likely to come into our
possession).

Usage Data” is data collected automatically either generated by the use of a service or from
the service infrastructure itself (for example, the duration of a page visit).

Cookies” are small pieces of data stored on your device (computer or mobile device).

Data Controller” means the natural or legal person who (either alone or jointly or in common
with other persons) determines the purposes for which and the manner in which any
personal information are, or are to be, processed. For the purpose of this Privacy Policy, we
are a Data Controller of your Personal Data.
Data Processor” (or Service Provider) means any natural or legal person who processes the
data on behalf of the Data Controller. We may use the services of various Service Providers
in order to process your data more effectively.

Data Subject” (or user) is any living individual who is using our service and is the subject of
Personal Data.

Information Collection and Use

We collect several different types of information for various purposes to provide and
improve our service to you.

Types of Data Collected

Personal Data

The personal data we collect depends on whether you just visit our site(s) or use our
services. If you visit our website, you do not need to provide any personal data. However,
your browser may transmit some data automatically, such as the date and time of retrieval
of our web pages, your browser types and settings, your operating systems, the last web
page you visited, data transmitted and the access status, and your IP address.

We collect the following personal data in the course of offering services when you provide it
to us:

Personal details: nickname(s); given name(s); contact details (including email address;
telephone number; address); and

Electronic identifying data: including cookies; online identifier; web forms; IP addresses;
activity logs; unique device identifiers and geo-location data.

Some of this personal data may be necessary for us to provide our services or perform our
contract with you. Where you don’t provide us with certain personal data we may be unable
to provide you or your organisation with the services requested.

If you use our services, certain personal data is required to fulfil the requirements of a
contractual or service relationship, which may exist between you and us.

We may use your Personal Data to contact you with newsletters, marketing or promotional
materials and other information that may be of interest to you. You may opt out of receiving
any, or all, of these communications from us by following the unsubscribe link or instructions
provided in any email we send or by contacting us.

Usage Data

We may also collect information on how our service or website is accessed and used
("Usage Data"). This Usage Data may include information such as your computer's Internet
Protocol address (IP address), browser type, browser version, the pages of our site that you
visit, the time and date of your visit, the time spent on those pages, unique device identifiers
and other diagnostic data.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our service and
hold certain information.

Cookies are files with small amount of data which may include an anonymous unique
identifier. Cookies are sent to your browser from a website and stored on your device.
Tracking technologies also used are beacons, tags, and scripts to collect and track
information and to improve and analyse our services.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being
sent. However, if you do not accept cookies, you may not be able to use some portions of
our service.

Examples of Cookies we use:

Session Cookies. We use Session Cookies to operate our service.

Preference Cookies. We use Preference Cookies to remember your preferences and

various settings.

Security Cookies. We use Security Cookies for security purposes.

Use of Data
We use the collected data for various purposes:

To provide and maintain our services;

To notify you about changes to our services;

To allow you to participate in interactive features of our services when you choose to do so;

To provide customer support;

To gather analysis or valuable information so that we can improve our services;

To monitor the usage of our services;

To conduct market research if you agree to be a participant. We or our research partners

collect and analyse your personal data which may include video recordings, your
demographic profile, financial profile, medical profile, and product preferences. We share
summaries of this information with our clients;
To detect, prevent and address technical issues; and

To provide you with news, annual reports, business updates, events, communications on
behalf of clients, personal introductions, product news, sector news, service news, thought
leadership and general information about other services and events which we offer that are
similar to those that you have already subscribed to or enquired about unless you have
opted not to receive such information.

Legal Basis for Processing Personal Data

Under General Data Protection Regulation
(GDPR)
If you are from the European Economic Area (EEA), our legal basis for collecting and using
the personal information described in this Privacy Policy depends on the Personal Data we
collect and the specific context in which we collect it.

We may process your Personal Data because:

We need to perform a contract with you;

You have given us permission to do so;

The processing is in our legitimate interests and it's not overridden by your rights; or

To comply with the law.

Retention of Data
We will retain your Personal Data only for as long as is necessary for the purposes set out
in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to
comply with our legal obligations (for example, if we are required to retain your data to
comply with applicable laws), resolve disputes, and enforce our legal agreements and
policies.

We will also retain Usage Data for internal analytic purposes. Usage Data is generally
retained for a shorter period of time, except when this data is used to strengthen the
security or to improve our services, or we are legally obligated to retain this data for longer
time periods.

Transfer of Data
Your information, including Personal Data, may be transferred to, and maintained on,
computers located outside of your state, province, country or other governmental jurisdiction
where the data protection laws may differ than those from your jurisdiction.

If you are located outside the European Union and choose to provide information to us,
please note that we transfer the data, including Personal Data, to the European Union and
process it there.

Your consent to this Privacy Policy followed by your submission of such information
represents your agreement to that transfer.

We will take all steps reasonably necessary to ensure that your data is treated securely and
in accordance with this Privacy Policy and no transfer of your Personal Data will take place
to an organisation or a country unless there are adequate controls in place including the
security of your data and other personal information.

Disclosure of Data
Disclosure for Law Enforcement
Under certain circumstances, we may be required to disclose your Personal Data if required
to do so by law or in response to valid requests by public authorities (e.g. a court or a
government agency).

Legal Requirements
We may disclose your Personal Data in the good faith belief that such action is necessary
to:

To comply with a legal obligation;

To protect and defend the rights or property of the Company;

To prevent or investigate possible wrongdoing in connection with the service;

To protect the personal safety of users of the service or the public; or

To protect against legal liability.

Security of Data
The security of your data is important to us but remember that no method of transmission
over the internet, or method of electronic storage is 100% secure. While we strive to use
commercially acceptable means to protect your Personal Data, we cannot guarantee its
absolute security.
Your Data Protection Rights Under General Data
Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data
protection rights. We take reasonable steps to allow you to correct, amend, delete, or limit
the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be
removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

The right to access, update or to delete the information we have on you. Whenever
made possible, you can access, update or request deletion of your Personal Data directly
within your account settings section. If you are unable to perform these actions yourself,
please contact us to assist you.

The right of rectification. You have the right to have your information rectified if that
information is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your Personal Data.

The right of restriction. You have the right to request that we restrict the processing of
your personal information.

The right to data portability. You have the right to be provided with a copy of the
information we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent. You also have the right to withdraw your consent at any
time where we relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use
of your Personal Data. For more information, please contact your local data protection
authority in the European Economic Area (EEA).

Service Providers
We may employ third party companies and individuals to facilitate our services ("Service
Providers"), to provide services on our behalf, to perform service-related services or to
assist us in analysing how our service is used.

These third parties have access to your Personal Data only to perform these tasks on our
behalf and are obligated not to disclose or use it for any other purpose.
Analytics
We may use third-party Service Providers to monitor and analyse the use of our services.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports
website traffic. Google uses the data collected to track and monitor the use of our Service.
This data is shared with other Google services. Google may use the collected data to
contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics
by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google
Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google
Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy
Terms web page: http://www.google.com/intl/en/policies/privacy/

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a
third-party link, you will be directed to that third party's site. We strongly advise you to
review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or
practices of any third-party sites or services.

Children's Privacy
Our Service does not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age
of 18. If you are a parent or guardian and you are aware that your child(ren) has provided
us with Personal Data, please contact us. If we become aware that we have collected
Personal Data from children without verification of parental consent, we take steps to
remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by
posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our service, prior to the change
becoming effective and update the "effective date" at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this
Privacy Policy are effective when they are posted on this page.

Effective date: May 24, 2018

Contact Us
If you have any questions about this Privacy Policy, please contact us:

By email: [email protected]

By mail: 65 Gresham Street, London EC2V 7NQ