Privacy Notice

1. Who we are and what we do

Who we are
We are Beeks Financial Cloud Group plc (“Beeks”, “us”, “we”, “our”). We are a limited company registered in Scotland under registration number SC521839 and we have our registered office at Riverside Building, 2 Kings Inch Way, Braehead, Renfrew, PA4 8YU, United Kingdom. We are registered with the UK supervisory authority, Information Commissioner’s Office (“ICO”) in relation to our processing of Personal Data under registration number ZA173130.

What we do
At Beeks, we provide low-latency, on-demand connectivity and analytics solutions, exclusively to the global capital markets and financial institutions. We and our affiliates, subsidiaries and related entities are committed to protecting the privacy and security of the Personal Data we process about you.

Controller
Unless we notify you otherwise, we are the controller of the Personal Data we process about you. This means that we decide what Personal Data to collect and how to process it.

2. Purpose of this privacy notice

The purpose of this privacy notice is to explain what Personal Data we collect about you and how we process it. This privacy notice also explains your rights, so please read it carefully. If you have any questions, you can contact us using the information provided below under the ‘How to contact us’ section.

3. Who this privacy notice applies to

This privacy notice applies to you if:

1. You visit our website
2. You purchase goods or services from us
3. You enquire about our products, services or events or are a business associate of ours
4. You sign up to receive newsletters and/or other promotional communications from us

4. What Personal Data is

‘Personal Data’ means any information from which someone can be identified either directly or indirectly. For example, you can be identified by your name or an online identifier.

5. Personal Data we collect

The type of Personal Data we collect about you will depend on our relationship with you. For the type of Personal Data we collect see the table below in the section entitled ‘Purposes, lawful bases and retention periods’.

6. How we collect your Personal Data

We collect most of the Personal Data directly from you in person, by telephone, text or email and/or via our website.

However, we may also collect your Personal Data from third parties such as others to whom you have provided consent.

7. Purposes, lawful bases and retention periods

We will only use your Personal Data when the law allows. Most commonly, we will use your Personal Data in the following circumstances:

Categories of Individuals	Categories of Personal Data	Purpose of Processing	Lawful Basis	Retention Period
Representative for a client	Name, name of company, business address, business email address, business phone number, job title	To administer the contract with our client	Legitimate interests of delivering our products and/or service	6 years following the date of the transaction
Business Associate (including representatives of former, existing and potential clients)	Name, name of company, business email address, job title	To send you newsletters and other promotional material	Legitimate interests of promoting our products, services and events	2 years following last meaningful contact
Business Associate (including representatives of former, existing and potential clients)	Name, name of company, business address, business email address, business phone number, job title, details of your query/enquiry	To answer your query / enquiry	Legitimate interests of answering your query	2 years following last meaningful contact
Any of the individuals mentioned above	Name, name of company, business address, business email address, business phone number, job title	For audit and reporting purposes and accounting and administrative tasks	Legal obligation	7 years from last financial year
Any of the individuals mentioned above	Name, name of company, business address, business email address, business phone number, job title	To respond to requests for information by competent public bodies and judicial authorities	Legal obligation	3 years following completion of the investigation
Any of the individuals mentioned above	Name, name of company, business address, business email address, business phone number, job title	To enforce, manage or assist with legal or other claims	Legitimate interests of enforcing, managing or assisting with legal or other claims	3 years following conclusion of the claims process

Where Personal Data is processed because it is necessary for the performance of a contract to which you are a party, we will be unable to provide our services without the required information.

8. Sharing your Personal Data

Within our organisation – Your Personal Data will only be shared inside our organisation with those who need to have access to it, such as those employees who are responsible for the deliverables under a client contract.

Service providers and suppliers – We may share your Personal Data with service providers and suppliers to our business who process Personal Data on our behalf. In most cases, our service providers and suppliers are data processors and may only use the data in line with our instructions and not for any other purpose. This and other obligations are agreed in the contract between us and the service providers and suppliers.

Mergers and acquisitions – We may share your Personal Data, if it is necessary to do so, in relation to a potential merger sale of company assets, financing or acquisition or all or part of our business to another company.

Legal obligation / court order / legal proceedings / regulatory requirement or similar – We may share your Personal Data, if it is necessary to do so, in relation to legal obligations, a court order, potential or existing legal proceedings, regulatory requirements or similar or to protect or defend ourselves or a third party.

Outsourced Data Protection Officer – We may share your Personal Data with our outsourced Data Protection Officer in relation to data protection matters.

9. International Transfers

We will process your Personal Data within the UK and the EU whenever possible. However, some of our service providers process your Personal Data outside of the UK and the EU.

We have taken appropriate steps to ensure that the Personal Data processed outside the UK has a sufficiently similar level of protection to that guaranteed in the UK. We do this by ensuring that:

• Your Personal Data is only processed in a country which the Secretary of State has confirmed has an adequate level of protection (an adequacy regulation) or
• We enter into an International Data Transfer Agreement (“IDTA”) with the receiving organisation and adopt supplementary measures, where necessary. (A copy of the IDTA can be found here Standard Data Protection Clauses to be issued by the Commissioner under S119A(1) Data Protection Act 2018
• When transferring your Personal Data to America, we rely on the UK-US Data Bridge, when possible.

10. Your rights and how to complain

You have certain rights in relation to the processing of your Personal Data, including to:

• Right to be informed

You have the right to know what personal data we collect about you, how we use it, for what purpose and in accordance with which lawful basis, who we share it with and how long we keep it. We use our privacy notice to explain this.

• Right of access (commonly known as a “Subject Access Request”)

You have the right to receive a copy of the Personal Data we hold about you.

• Right to rectification

You have the right to have any incomplete or inaccurate information we hold about you corrected.

• Right to erasure (commonly known as the right to be forgotten)

You have the right to ask us to delete your Personal Data.

• Right to object to processing

You have the right to object to us processing your Personal Data. If you object to us using your Personal Data for marketing purposes, we will stop sending you marketing material.

• Right to restrict processing

You have the right to restrict our use of your Personal Data.

• Right to portability

You have the right to ask us to transfer your Personal Data to another party.

• Automated decision-making

You have the right not to be subject to a decision based solely on automated processing which will significantly affect you. We do not use automated decision-making.

• Right to withdraw consent

If you have provided your consent for us to process your Personal Data for a specific purpose, you have the right to withdraw your consent at any time. If you do withdraw your consent, we will no longer process your information for the purpose(s) you originally agreed to, unless we are permitted by law to do so.

• Right to lodge a complaint

You have the right to lodge a complaint with the relevant supervisory authority, if you are concerned about the way in which we are handling your Personal Data. The supervisory authority in the UK is the Information Commissioner’s Office who can be contacted online at:

Contact us ICO or by telephone on 0303 123 1113

How to exercise your rights
You will not usually need to pay a fee to exercise any of the above rights. However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

If you wish to exercise your rights, you may contact us using the details set out below within the section called ‘How to contact us and our Data Protection Officer’. We may need to request specific information from you to confirm your identity before we can process your request. Once in receipt of this, we will process your request without undue delay and within one month. In some cases, such as with complex requests, it may take us longer than this and, if so, we will keep you updated.

11. Children’s Privacy

We do not offer our products and services to children and we do not knowingly collect Personal Data of children.

12. How to contact us and our Data Protection Officer

If you wish to contact us or our Data Protection Officer in relation to this privacy notice or if you wish to exercise any of your rights outlined above you can do so as follows:

Contact us as at:
lesley.officer@beeksgroup.com

Riverside Building
2 Kings Inch Way
Braehead
Renfrew PA4 8YU
United Kingdom

Tel: 01505 800603

Please mark your communications FAO the ‘Data Protection Officer’.

13. Changes to this privacy notice

We may update this notice (and any supplemental privacy notice), from time to time as shown below. We will notify of the changes where required by applicable law to do so.

Last modified 19th February 2025