Privacy notice

CPPGroup Limited respects your privacy and is committed to protecting your personal data.

CPPGroup Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website at https://corporate.cppgroup.com/ (“Site”) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1. Important information and who we are Purpose of this privacy notice

This privacy notice aims to give you information on how CPPGroup Limited collects and processes your personal data through your use of this Site, including any data you may provide to us (for example, if choose to sign up on the Site to receive shareholder updates about
CPPGroup Limited by email).

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

It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.

Controller and Contact Details

CPPGroup Limited is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice). We are a company registered in England and Wales under company number 07151159. Our registered office is 19th Floor, 51 Lime Street, London,
EC3M 7DQ. We are part of the CPPGroup Limited group of companies (“CPP Group”). Our registration number with the ICO is Z2162480.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

by post at: CPPGroup Limited, 19th Floor, 51 Lime Street, London, EC3M 7DQ; or
by email at: [email protected].

You have the right to make a complaint at any time to the Information Commissioner (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice

We may change this privacy notice from time to time by updating this page. We will not necessarily bring changes or updates to your attention so please revisit this page periodically to re-read this privacy notice and to ensure you are aware of any changes when you visit the Site. If there are substantive changes, we may at our discretion bring those to your attention, for example, by a message posted on the landing page of the Site.

Third-party links

This Site may include links to third-party websites, which may include websites provided by other companies within the CPP Group. Clicking on those links may allow these third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices. When you leave our Site, we encourage you to read the privacy notice of every website you visit.

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 and process the following data about you:
Information you give us. This may include your name, phone number and email address. If you choose to sign up on the Site to receive shareholder updates about CPPGroup Limited by email, we will collect the email address you provide for that purpose.

Information we automatically collect about you. This may include:

technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, the type of device you are using to access the Site, resolution of the screen and operating system; and
information about your visit such as whether you have visited the Site before and information collected through the use of Google Analytics which is anonymised. We collect statistical information such as the number of visitors to certain areas of the Site during a given period. This information is collected for statistical review only and it cannot be used to identify an individual user.

If you fail to provide personal data

Where we need to collect personal data by law, or in order to respond to a request or query you have raised, for example through the ‘Contact Us’ form on the Site, and you fail to provide that data when requested, we may not be able to respond to you and/or action your request.

Providing your email address to receive shareholder updates is entirely voluntary. If you choose not to sign up, you will not receive these email updates, but this will not affect your rights as a shareholder. Signing up (or choosing not to) does not change how you receive formal shareholder communications, such as notices of general meetings and annual reports, which will continue to be sent to you in accordance with our articles of association and applicable law.

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 details of your identity and contact details by filling in the ‘Contact Us’ form on our Site, by signing up on our Site to receive shareholder updates by email, or by corresponding with us by phone, e-mail or otherwise.
Automated technologies or interactions. As you interact with our Site, we may automatically collect technical data about your equipment, browsing actions and patterns as described in section 2 above. Google Analytics will collect information about your online activity on the Site, such as the web pages you visit, the links you click, and the searches you conduct on the Site. For more information on our use of Google Analytics, please see our Cookie Policy.

4. 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 bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To respond to any communication you send to us including via the ‘Contact Us’ form on the Site	Information which you provide to us, for example contact details	Necessary for our legitimate interests (for running our business, to develop our business)
If you have signed up on the Site to receive shareholder updates, to send you updates about CPPGroup Limited by email (such as company announcements, results and other company news) and to manage your subscription, including processing any request to unsubscribe	Information which you provide to us, namely your email address, and your subscription preferences	Your consent. You can withdraw your consent at any time by unsubscribing as outlined in any update email or by contacting us at [email protected]. Where we keep a record of your consent and of any request to unsubscribe, this is necessary for our legitimate interests (to demonstrate our compliance with data protection law and to ensure we respect your preferences)
To administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.	Information which we automatically collect about you, such as technical data	Necessary for our legitimate interests (for running our business, provision of administration and IT services, to keep our Site updated and relevant, to develop our products/services and grow our business)
To improve the Site to ensure that content is presented in the most effective manner for you and for your computer.	Information which we automatically collect about you, such as technical data	Necessary for our legitimate interests (for running our business, provision of administration and IT services, to keep our Site updated and relevant, to develop our products/services and grow our business)

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.

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 Site may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

Service Providers

Your personal data will be shared with authorised third party service providers who perform services on our behalf (which will include other companies within the CPP Group which provide services to us), e.g. providing IT support and maintenance and sending shareholder email updates on our behalf. These service providers may have access to personal information needed to perform their functions on our behalf but are not permitted to share or to use such information for any other purpose. We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

Other companies within the CPP Group

You agree that we have the right to share your personal information with any member of the CPP Group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. For example, if you contact us in relation to a contract that you hold with one of our group companies, your information will be shared with that company to enable them to respond.

6. International transfers

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

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
If we use certain service providers, we may use specific contracts which give personal data the same protection it has in the UK and EEA.
If we use providers based in the US, we may transfer data to them if the provider has signed up to the EU-US Data Privacy Framework regime.

7. Data security

We have put in place appropriate 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 technical, organisational and administrative security measures and 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.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. If you have signed up to receive shareholder updates, we will keep your email address on our distribution list until you unsubscribe or withdraw your consent, or until we stop sending these updates. Once you unsubscribe, we will remove your email address from our distribution list promptly.

9. Your legal rights

Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. If you think any information we have about you is incorrect or incomplete, please contact us as soon as you can using the contact details set out below. We will correct or update any information as soon as possible.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information 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 information 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, if applicable, at the time of your request.
Object to processing of your personal information 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.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
Withdraw your consent at any time where we are relying on consent to process your personal information (for example, to send you shareholder updates by email). Withdrawing your consent will not affect the lawfulness of any processing carried out before you withdrew it.

If you want to review, verify, correct or request erasure of your personal data, object to the
processing of your personal data, withdraw your consent, or request that we transfer a copy of
your personal information to another party, you can contact us:

by post at: CPPGroup Limited, 19th Floor, 51 Lime Street, London, EC3M 7DQ
by email at: [email protected]

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

We may need to request specific information from you to help confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

We will try to respond to all legitimate requests within one month. Occasionally it may 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.