Institutional Approach to Digital Assets

This site and the information on it is neither directed at nor made available to retail clients. It is directed only at persons who are professional investors (for the purposes of the Alternative Investment Fund Managers Directive (2011/61/EU) (known as 'AIFMD'); professional clients or eligible counterparties for the purposes of the Markets in Financial Instruments Directive (Directive 2004/39/EC) (known as 'MiFID'); or as otherwise defined under applicable local regulations and at whom this site and the information on it may lawfully be directed in any relevant jurisdiction. The definition of professional investor under AIFMD can be found here and the definitions of professional client and eligible counterparty under MiFID can be found here. Please contact us if you require any further information on your status.

FOR HONG KONG USERS: This site and the information on it is directed only at, and made available only to, professional investors as defined in the Securities and Futures Ordinance (Cap. 571, the laws of Hong Kong, "the Ordinance") and its subsidiary legislation, Securities and Futures (Professional Investor) Rules ("PI Rules"). Any investment/subscription from a Hong Kong investor will only be accepted if such investor is a professional investor. Please refer to the links for the definitions of professional investors under the Ordinance and PI Rules. Please contact us if you require any further information on your status.

By accepting these Terms of Use, you hereby certify that you are a Professional Investor, Professional Client or an Eligible Counterparty.

About Nickel

The Nickel website 'nickel.digital' ('our site') is issued for all purposes by Nickel Digital Asset Management Ltd ('NDAM Ltd'). We are registered with the Financial Conduct Authority to carry on fund services business as an investment manager.

Your use of our site

These Terms of Use set out the terms on which you may make use of our site and apply to every page on our site, whether or not such pages are individually disclaimed. Please read these Terms of Use carefully before you start to use our site. By using our site, you have indicated that you accept these Terms of Use and that you agree to abide by them. If you do not agree to these Terms of Use, please refrain from using our site. These Terms of Use also incorporate our cookies and privacy policy and all other rules, policies and procedures that may be published from time to time on our site, each of which is incorporated by reference and each of which may be updated by us from time to time without notice to you.

In the United Kingdom, the issue and communication of this website has been approved by NDAM. If you are in the United Kingdom or elsewhere in the EEA, you should note that our site may contain information or documents which constitute a financial promotion for the purposes of the Financial Services and Markets Act 2000 and the FCA Rules. Accordingly, our site is issued only to and/or is directed only at persons who are professional clients or eligible counterparties as defined in the FCA Rules. We neither provide investment advice to, nor receive and transmit orders from, investors in any funds nor do we carry on any other activities with or for such investors that constitute 'MiFID or equivalent third country business' for the purposes of the FCA Rules.

We may revise these Terms of Use from time to time by updating this page. The revised Terms of Use will take effect when they are posted. You are expected to check this page from time to time and to take notice of any changes we may have made, as by using our site you acknowledge that you have accepted any such amendments.

You must NOT use our site (or permit or procure others to use it) as follows:

(A) for any unlawful, improper or illegal purpose or activity;

(B) to violate our or any third party's copyright, trademark, proprietary or other intellectual property rights;

(C) to damage our name or reputation or that of our affiliates or any third parties;

(D) to impersonate any of our employees or other person or use a false name while using our site or implying an association with us;

(E) to penetrate our security measures or other entities' systems ("hacking");

(F) to generate excessive amounts of internet traffic, to interfere with our network or other's use of our site or to engage in activities designed to or having the effect of degrading or denying service to users of our site or others;

(G) to introduce viruses, worms, harmful code and/or Trojan horses onto the internet or into our site or any other entity's systems and it is your responsibility to ensure that whatever you download or select for your use from our site is free from such items; and/or

(H) to transmit confidential or proprietary information, except solely at your own risk.

Marketing restrictions

The distribution of information on this site may be restricted by law in certain countries. This site and the information on it is not addressed to any person resident in the territory or country or jurisdiction where such distribution would be contrary to local law or regulation. Some funds are not available, and offering materials relating to them will not be distributed, to persons resident in any country where such distribution would be contrary to local law or regulation. Compliance with law and regulation

When using our site, you agree you will comply with all applicable local, national and international laws and regulations, including those related to data privacy, international communications and exportation of technical or personal data. It may be illegal to view and/or download the information contained on our site in certain countries and we and our affiliates disclaim all responsibility if you access or download any information from our site in breach of any law or regulation of the country in which you are a citizen or in which you are resident or domiciled.

Accuracy of information

We have taken reasonable care to ensure that the information on our site is accurate, current, complete, fit for its intended purpose and compliant with applicable law and regulation as at the date of issue. However, errors or omissions may occur due to circumstances beyond our control and no warranty is given, or representation made, regarding the accuracy, validity or completeness of the information on our site and no liability is accepted by such persons for the accuracy or completeness of such information. You must conduct your own due diligence and investigations rather than relying on any information on our site. Any person who acts upon, or changes his or her investment position in reliance on, the information contained on our site does so entirely at his or her own risk.

Access

We reserve the right to deny you access to our site, or immediately to suspend or terminate your access to our site, or to disable any user name or password (whether chosen by you or allocated by us) at any time (in our sole discretion).

Liability for use of our site

Access to our site is permitted on a temporary basis and we reserve the right to withdraw or amend the service and/or information we provide on our site without notice. We do not accept any liability if for any reason our site is unavailable at any time or for any period. Our site is provided for informational purposes only and is not intended to constitute an invitation, solicitation or offer to subscribe for or purchase any investments, products or services (including, for the avoidance of doubt, any units or shares in any fund), nor shall it, or the fact of its issuance, form the basis of, or be relied on in connection with, any contract.

The information and opinions contained in our site have been compiled, or arrived at, by us from sources believed by us to be reliable as at the date of publication. However, the information and any opinions contained on our site are subject to change, are for background purposes only and are not to be relied upon as investment advice or interpreted as a recommendation. We, our affiliates and other third parties connected to us do not accept any responsibility for any reliance which is placed by any visitor to our site, or by anyone who may be informed of any of its contents, on any information or opinions which are expressed herein and, to the extent permitted by law, expressly exclude all conditions, warranties, representations, undertakings and other terms which might otherwise be implied by statute, common law or in equity.

Our site is not intended to provide a sufficient basis on which to make any investment decision and you should not solely rely on it in evaluating the merits of investing in any investments, products or services referred to on our site. Any decision to purchase securities or interests with respect to any funds must only be made having thoroughly read the relevant prospectus or offering memorandum for the relevant fund, including any supplements thereto, which must be received and reviewed prior to any investment decision and which may contain information which is different from the information and opinions contained on our site. Any person subscribing for an investment, product or service referred to on our site must be able to bear the risks involved and must meet the suitability requirements relating to such investment, product or service. Some or all alternative investment programs may not be suitable for certain investors.

We, our affiliates and other third parties connected to us therefore expressly exclude any liability and responsibility arising from any reliance placed on such materials and information by any visitor to our site, or by anyone who may be informed of any of its contents, for (i) the accuracy, validity, timeliness, merchantability or completeness of, any information or data (whether prepared by us or by any third party) for any particular purpose or use or that the information or data will be free from error and (ii) any direct, indirect or consequential loss or damage of any kind incurred by any visitor to our site, or by anyone who may be informed of any of its contents, in connection with our site or in reliance on the information or opinions contained in it, or in connection with the use, inability to use, or results of the use of our site or any websites linked to it or materials posted on it. This does not affect our liability for any loss or damage which cannot be excluded or limited under applicable law. The internet is not a completely reliable transmission medium and neither we nor any of our affiliates accept any liability for any data transmission errors such as data loss or damage or alteration of any kind or for the security or confidentiality of information transmitted across the internet to or from us or any of our affiliates. Any such transmission of information is entirely at your own risk.

Linked websites

Should you leave our site via a link contained within our site and view content that is not provided by us, you do so at your own risk. We provide links only as a convenience and without liability. In particular, and without limitation, you understand and agree that the ability to link to another website and the fact that a link exists does not mean that we endorse or guarantee such site, the site sponsor or the site contents. The content which you access via such links will not have been developed, checked for accuracy, or otherwise reviewed by us. We make no guarantees or representations as to, and shall have no liability for, any electronic content delivered by any third party, including, without limitation, the accuracy, subject matter, quality, sequence or timeliness of any electronic content. Your reliance on any information contained on any site reached through a link shall be your own responsibility. When you leave our site, unless otherwise indicated, you will be subject to the terms of use and privacy policies of the new website which you are visiting. If you reached our site via a link, please be advised that the ability to link to our site and the fact that a link exists does not mean that we necessarily endorse, support, sanction, encourage, verify, or agree with the comments, opinions, or statements posted on the website from which you linked to our site (the 'Linking Site'). We are not responsible for any damages or losses arising from any delays, defects or omissions that may exist in the services, information or other content provided in the Linking Site. We make no guarantee or representation as to, and shall have no liability for, any content on any Linking Site, including, without limitation, the accuracy, subject matter, quality, sequence or timeliness of any such content.

Indemnity

You agree to indemnify, defend, and hold harmless us, our affiliates and our officers, partners, employees, and agents from and against any and all claims, liabilities, damages, losses, or expenses, including legal fees and costs, arising out of or in any way connected with your breach of the Terms of Use and/or access to or use of our site. Intellectual property rights

We are the owner or the licensee of all intellectual property rights in our site, and in the materials published on it. Those works are protected by laws and treaties around the world. All such rights are reserved. You may use the materials on our site and download and reproduce them in hard copy for your own reference only. Such materials may not otherwise be reproduced, distributed, stored in a data retrieval system or transmitted, in any form or by any means (electronic, mechanical, photocopying, recording or otherwise) without our prior written consent. Nothing on our site should be construed as granting any licence or right in relation to any of our trademarks or those of our affiliates or any third party.

Severability

If any specific term or condition of these Terms of Use is determined by a court of competent jurisdiction to be invalid, void or unenforceable, that determination shall not affect the validity of the remaining provisions of these Terms of Use. Headings used in these Terms of Use are for convenience, are not substantive and shall not be used to interpret or construe any of the provisions contained in these Terms of Use. When used in these Terms of Use the words 'includes', and 'including' shall be deemed to be followed by the phrase 'without limitation'.

Material Interests

We and our partners, officers and/or employees may have holdings in the investment funds referred to on our site and may otherwise be interested in transactions that you effect in those funds.

Governing Law

These Terms of Use and any non-contractual obligations arising from or connected with them shall be governed by and shall be construed in accordance with English law. English courts will have exclusive jurisdiction over any dispute arising from, or related to, use of our site (whether arising out of or in connection with contractual or non-contractual obligations) ('proceedings') and it is a condition of using our site that you waive any objection to proceedings in such courts on the grounds of venue or that proceedings have been brought in an inconvenient forum, although we retain the right to bring proceedings against you for breach of these Terms of Use in your country of residence or any other relevant country.

Third parties

For EEA Users: we shall have the benefit of the rights conferred on us by these Terms of Use but otherwise no person who is not a party to these Terms of Use may enforce its terms under the Contracts (Rights of Third Parties) Act 1999.

Entire agreement

These Terms of Use and our Disclaimer shall form the entire agreement between you and us in relation to your use of our site.

Contact us

If you have any enquiries in relation to our site or the information on it, please contact ir@nickel.digital

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For information about how we collect, use, and share other types of information, please read our privacy policy.


I. What is a Cookie?

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
You can find out more about cookies at http://www.allaboutcookies.org.


II. Cookies that We Use

We use the following cookies:

Strictly necessary cookies
These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. Without these cookies, our website may not work properly or at all. We do not track your personal data with the strictly necessary cookies. Therefore, we are not legally obliged to receive your consent to use these cookies on our website.

Analytical or performance cookies
These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies
These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences.
There are also two different types of cookies based on when they expire.

Session cookies
Session cookies are those that expire at the end of your browser session, which is when you exit your browser. These cookies remember the page you visit and therefore support navigation. These cookies will no longer functional once you close your browser. Therefore, these cookies are not usually stored beyond the browser session.

Persistent cookies
Persistent cookies are stored on your equipment between browsing sessions. They therefore enable our website to "recognise" you on his return, to remember your preferences. They may also be used to track the user's browsing activity across different websites and to build up a detailed profile of his browsing behaviour for targeting advertising. For this reason, persistent cookies are generally considered to be more privacy-intrusive than session cookies.
There are two different types of cookies based on who planted them on our website.

First-party cookies
First-party cookies are planted by Nickel on this website. This involves assigning a unique identity to the user by setting the cookie to either the user's browser and/or his hard drive with a view to tracking the user's journey on the website. We use first-party cookies for session management and personalisation.

Third-party cookies
Third-party cookies are cookies planted by third-parties other than us.


III. Your Rights

You can always change your cookie preferences at any time. If you change the settings on your web browser or delete your cookies, you will be presented with the consent option again the next time you visit our Sites. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of our website may not operate correctly.

Find out how to manage cookies on popular browsers:

-      Google Chrome
-      Microsoft Edge
-      Mozilla Firefox
-      Opera
-      Apple Safari

To find information relating to other browsers, please visit the browser developer's website.
If you have questions on our use of cookies, please email dp@nickel.digital.

Introduction

Welcome to the Nickel Digital's privacy policy.

Nickel Digital (collectively referred to as "we", "us" or "our" in this privacy policy) 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) 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 Nickel Digital collects and processes your personal data through your use of this website, including any data you may provide through this website when you request information about the investment funds.

It is important that you read this privacy policy together with any other privacy policy or fair processing 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 and Contact Details

Nickel Digital is the controller and responsible for your personal data.
If you have any questions about this privacy policy, including any requests thereof, please contact us at dp@nickel.digital.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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 policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 03 August 2022.
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.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy 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, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes title, first name and last name.
• Contact Data includes email address and telephone numbers.
• Financial Data includes bank account and financial information.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website and services.

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.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel our service you have with us but we will notify you if this is the case at the time.


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, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our services;
• request information to be sent to you; or
• give us feedback or contact us.
• 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, server logs 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 may receive personal data about you from various third parties and public sources.

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:

• Where we need to perform the contract, we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

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

We have set out below 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.

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.

1. To register you as a new investor for the performance of a contract with you: Identity and Contact Data
2. To manage our relationship with you which will include notifying you about changes to our terms or privacy policy (necessary to comply with a legal obligation and for legitimate interest): Identity, Contact Data
3. To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data): Identity, Contact and Technical Data
4. To deliver relevant website content to you and measure or understand its effectiveness (Necessary for our legitimate interests to study how site visitors use our services, to develop them, to grow our business and to inform our business strategy): Identity, Contact and Technical Data
5. To use data analytics to improve our website, services, marketing, customer relationships and experiences (necessary for our legitimate interests to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy): Technical and Usage Data
6. To make suggestions and recommendations to you about services that may be of interest to you (necessary for our legitimate interests (o develop our services and grow our business): Identity, Contact, Technical and Usage Data

Marketing

We strive to provide you with choices regarding certain personal data uses. 
Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile 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 services and offers may be relevant for you.

Third-party marketing

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

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.

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.

5.  Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

• Internal third parties. Please note that we may on occasion be required to share your information with our group companies around the world. We have procedures in place, as defined below, to ensure the protection of your information and we have taken steps to ensure that all such entities keep your personal information confidential and secure and only use it for the purposes that we have specified and have informed you of.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6.  International transfers

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. 
Whenever we transfer your personal data out of the UK, 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 there is no adequate level of protection, we will then use standard contractual clauses in line with the ICO’s requirements.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

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 will maintain the confidentiality of and protect your information in accordance with our Privacy Notice and all applicable laws.
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.

8.  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.

In some circumstances we may 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.

9.  Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at dp@nickel.digital.
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.

10.  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. 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.

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, 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's 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 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.