PRIVACY POLICY

IMPORTANT LEGAL NOTICE

We are committed to protecting your privacy. This policy outlines the information we collect from you, how we use this information and your rights in relation to it.

We are committed to managing personal information in accordance with the United Kingdom Privacy Principles under the Privacy Act 1998 , the General Data Protection Regulation2018 6 (DPA) and in accordance with other applicable privacy laws.

By accepting this Privacy Policy, you consent to us collecting, using and disclosing your Personal Information in accordance with the terms of this policy.

Effective Date: 01/09/2010

What personal information do we collect?

When you contact us through our web enquiry service, we may collect the following information from you:

• Your name;

• Email address;

• Phone number; and

• Details of the nature of your enquiry.

If you are a candidate for employment, we may collect additional information that is relevant to your employment such as work and education history.

If you enter into an agreement with us for the provision of services, then we collect additional information such as:

• Your name;

• Email address;

• Phone number;

• Your payment details;

• Photo identification;

• Proof of residential address;

• Date of birth;

• Postal address;

• Biometric information;

• Next of kin contact information (including their name, contact number, relationship to you and date of birth); and

• Proof of identity information pursuant to our legal obligations as explained in further detail below.

We also collect your personal data (such as proof of identity information) when you attend our premises.

Why do we store your personal information?

We collect information primarily to allow you to receive our services and use our website.

Some of the reasons we store your information include to:

• enter into a licence agreement for a vault or safe deposit box

• enable you to make an enquiry on our website

• administer your account

• check your credit history

• record data and analytics that allow us to improve our website

• respond to data requests from you and to fulfil our commitments to data storage and freedom of information under the relevant governing agreements and regulations stated above

• fulfil our reporting obligations to any relevant tax and regulatory bodies

• properly perform our obligations to you in providing any services

• maintain accounts records, tracing and verification in accordance with our security procedures

• comply with our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2000 , including but not limited to identity verification requirements

• recruit for Bevaud Storage Vaults

While most of our data in relation to you comes from collecting it directly from yourself, we may from time to time work with third parties who assist us in our business. Your data is protected by their relevant privacy policies and we take steps to ensure that any data we collect is in line with relevant legislation and best practice.

When do we collect your personal information?

We collect your personal information when you attend our premises, when you use our services and when you interact with us via phone, email or in person.

Examples of when we collect your personal information include:

• When you apply for a licence for a vault or safe deposit box;

• When you attend our premises;

• When you provide us with personal information through the web enquiry service;

• When we process payments in exchange for any services;

• When you contact us via phone, email, letter or in person; and

• If you are a candidate for employment, when you complete forms as part of your employment application.

What happens when we’re unable to collect your personal information?

If we are unable to collect your personal information, we may not be able to fulfil our obligations to you including providing our secure storage services. Your experience when interacting with us may be delayed or not as efficient as you would like.

How do we store your personal information?

We take every effort to store your personal information safely. We may hold your personal information either in electronic or hard copy form. When we store information electronically, this may be on our computer systems, databases, software programs, internet servers and hosted internet solutions. We take every effort to keep your information safe in accordance with relevant government regulation and requirements. Our servers, computer systems and internet hosting are protected through necessary security systems including physical locks, firewalls, security systems and passwords.

How we share your data

We do not sell your personal information to third parties. However, we may share some of your data with our third-party partners in the provision of the agreed services with your consent. When this is done, our partners are obligated to only use your data for the reasons agreed with us and have committed to not misuse or sell your data in any way. Your personal data may be shared to the following partners:

• Our employees, contractors or service providers in the instance that this is necessary to provide services to you;

• Our business advisors including accountants, lawyers and other business professionals where reasonably required for them to fulfil their obligations to us; or

• If required by law to any person or body authorised by such law.

Your personal information may be disclosed to third parties if disclosure is required by law. If we sell our business, or we have a change in control, your personal information will be disclosed and transferred to the new owner/controller for that purpose.

We do not sell or otherwise disclose your personal information for marketing purposes unless you have specifically consented to such marketing.

We are not liable for any loss, damage or claim arising out of a third party’s use of your personal information where we were authorised by you or law to provide that third party with your personal information.

How long do we store your personal information?

We retain your personal information for as long as is needed for us to fulfil our obligations to you, for example to provide services. We may also need to store your personal information to comply with any tax or governing bodies. When we no longer need to store your data for these reasons, we will either delete or sufficiently anonymise this. For the avoidance of doubt, we will delete all biometric finger and hand scans when your agreement with us is terminated. Please note that we may have a legal obligation to retain copies of your information in certain circumstances for a particular period of time, such as to comply with our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2000

Do we disclose your personal information overseas?

Bevaud Storage is based in United Kingdom so the majority of our service providers are United Kingdom based. However, we may from time to time collaborate with overseas partners. We only ever disclose your personal information outside the jurisdiction it was collected where we are permitted to do so under applicable privacy laws. This means that we have taken all necessary steps to keep your information safe as per the relevant privacy regulations.

Changes to our policies

We may make changes to this policy from time to time. Our current policy will be available on our website or a hard copy may be provided to you upon request. If you continue to use our services after any update to this policy, you agree to the terms of the updated policy and consent to the use of personal information in accordance with the updated policy.

Privacy Complaints

If you believe we have breached our privacy rights at any time, please send us an email at compliance@bevaudstorage.org so our privacy office can investigate and respond to you. All such enquiries or complaints will be taken seriously and handled with impartiality and discretion. If you wish to submit a complaint, please provide us with all relevant details such as the date and time of the incident or communication, the circumstances surrounding the event and your concerns about what was said or done.

If you have complained about something that is not covered in the relevant privacy laws, we will explain why we are unable to take further action. Please allow a few days for us to investigate and respond to any privacy complaints.