Haycen Ltd (“We”) are committed to protecting and respecting your privacy. We will only process your personal data where permitted by applicable data protection laws, including the General Data Protection Regulation (“UK GDPR”). This policy (together with our terms of use) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Information We May Collect From You

Personal information is typically data that identifies an individual or relates to an identifiable individual. This includes information clients provide to Haycen for the use of services provided, information that is collected about clients and counterparties automatically or upon request, and information the firm obtains from affiliates and third parties. All this information is either required by law for AML/CFT obligations, necessary to provide the requested services, or is relevant for certain specified purposes as follows:

• To maintain legal and regulatory compliance
• To enforce our terms in our user agreement and other agreements
• To detect and prevent fraud and/or funds loss
• To provide Haycen's Services
• To provide service-related communications
• To provide customer service
• To ensure network and information security
• For sales and marketing activities
• For any purpose that clients provide their consent for

Clients are requested to further give their explicit, informed, and specific consent in a written form for the processing of personal data which are not within the scope of AML/CFT obligations pursuing Article 4, Sec. 11, and Art. 6 GDPR. Data subjects are always informed of all purposes of processing and Haycen must obtain consent for each of the defined purposes to ensure transparency and execution of rights.

Data We May Collect and Process

We may collect and process the following data about you:

Data We May Collect and Process

Where we intend to process the personal data that you have provided for a purpose other than that for which the personal data was collected, we shall provide you with information on that other purpose and with any relevant further information prior to that further processing.

We may receive information about you from other sources, such as conference organisers and marketing companies. Where we process this information, the legal basis for the processing will be consent. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Cookies

Our sites use cookies to distinguish you from other users of a site. This helps us to provide you with a good experience when you browse our sites and also allows us to improve our sites. Cookies are small text files which a website may put on your computer or mobile device when you first visit a site or page. We use cookies on our sites to improve their performance and enhance your user experience.

If you do not want to receive cookies, you may choose to opt-out by changing your browser settings. Most browsers allow you to turn off cookies. Switching off cookies may restrict your use of a site and/or delay or adversely affect the way in which it operates.

Listed below are the cookies being used on the Haycen website, their source, and supposed usage:

First Party Cookies

Cookies that are set by the website and can only be used by the website.

• To persist user session so they stay logged in on the website (session only)
• To store currently logged in user details to pre-fill form data
• To authorise the interface with Haycen servers as part of user registration and onboarding
• To save user's account preferences

Third Party Cookies

Cookies that are not set by the website owner and are primarily used for analytical data of that service or feature.

Google

• To track current active users
• To get visits based on geolocation
• To get most visited pages and duration of user session per visit
• To get devices commonly used to access the site
• To get traffic based on time of day
• To know how users get referred to the website

Marketing

From time to time, we may send you information regarding that which we perceive may be of interest to you or your business. You may receive this information by letter, telephone, or email. If at any time you prefer not to receive further communications from us in any or all forms (except in connection with information, products or services that you specifically request) you will have the ability to opt-out from such communications by means of a link provided in emails that are sent to you by us.

Disclosure of Your Information

We may share your information with selected third parties including:

• Third party service providers, for example, our recruitment applicant tracking system provider, professional advisors including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Analytics and search engine providers that assist us in the improvement and optimisation of our sites. Any party which acquires Haycen or substantially all of its assets, in which case personal data held by it about its customers will be one of the transferred assets.
• Any other party as required by law, or in order to enforce or apply our terms of use and other agreements or to protect the rights, property, or safety of Haycen, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where We Store Your Personal Data

The data that we collect from you may be transferred to, stored, and processed in any destination where Haycen or its affiliates, subsidiaries, or facilities used by third party service providers have a presence. We will only transfer your data to a country outside the European Economic Area where that country ensures an adequate level of data protection within the meaning of the GDPR.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of a site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We will implement appropriate technical and organisational measures to protect your data, taking into account the nature, scope, context and purpose of the processing and the risks involved in processing. Unfortunately, the transmission of information via the internet is not completely secure. Although we will seek to protect your personal data, we cannot guarantee the security of your data transmitted to a site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

How Long Will We Store Your Personal Data

The personal data that we collect from you will be stored only for so long as is necessary to fulfil the purpose for which the data was collected, or to comply with applicable legal, tax or regulatory requirements.

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 requirements.

Your Rights

If you have rights under the GDPR, you have the following rights:

• To access your data (subject to the provisions of Article 15 of the GDPR)
• To request that inaccurate data be rectified (subject to the provisions of Article 16 of the GDPR)
• To request that your personal data be erased (subject to the provisions of Article 17 of the GDPR)
• To restrict the processing of your data (subject to the provisions of Article 18 of the GDPR)
• To transfer your data between controllers (subject to the provisions of Article 20 of the GDPR)
• To object to processing of personal data (subject to the provisions of Article 21 of the GDPR)

Should you wish to exercise any of your rights under the GDPR please contact Haycen at the address detailed below.

Changes to Our Privacy Policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

Contact

Questions, comments and requests regarding this privacy policy should be sent to Haycen Ltd, 13 Hursley Road, Chandler's Ford, Eastleigh, Hampshire, England, SO53 2FW, registered in England and Wales no. 12031746.

If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, please contact us by writing to us at the following address dataprotection@haycen.com.

These terms of use tell you the terms on which you may make use of our website. By using our site, you confirm that you accept these terms of use and that you agree to comply with them. If you do not agree to these terms of use, you must not use our site.

Other Applicable Terms

These terms of use refer to our Privacy Policy, which sets out the terms on which we process any personal data we collect from you, or that you provide to us. By using our site, you consent to such processing, and you warrant that all data provided by you is accurate.

Information About Us

www.haycen.com is operated by Haycen Ltd (“We”).

Changes to These Terms

We may revise these terms of use at any time by amending this page. Please check this page from time to time to take notice of any changes we make, as they are binding on you.

Changes to Our Site

We may update our site from time to time and may change the content at any time. However, please note that any of the content on our site may be out of date at any given time, and we are under no obligation to update it. We do not guarantee that our site, or any content on it, will be free from errors or omissions.

Accessing Our Site

Our site is made available free of charge. We do not guarantee that our site, or any content on it, will always be available or be uninterrupted. Access to our site is permitted on a temporary basis. We may suspend, withdraw, discontinue or change all or any part of the site without notice. We will not be liable to you if for any reason the site is unavailable at any time or for any period.

You are responsible for making all arrangements necessary for you to have access to our site. You are also responsible for ensuring that all persons who access the site through your internet connection are aware of these terms of use and other applicable terms and conditions, and that they comply with them.

Intellectual Property Rights

We are the owner or licensee of all intellectual property rights on our site, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved. You must not use any part of the content on our site for commercial or business purposes without obtaining a licence to do so from us or our licensors.

No Reliance on Information

The content on our site is provided for general information only. It is not intended to amount to advice (including investment advice) on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on our site. Although we make reasonable efforts to update the information on our site, we make no representations, warranties or guarantees, whether express or implied, that the content on our site is accurate, complete or up to date.

Limitation of Our Liability

Nothing in these terms of use excludes or limits our liability for death or personal injury arising from our negligence, or our fraud or fraudulent misrepresentation, or any other liability that cannot be excluded or limited by English law. To the extent permitted by law, we exclude all conditions, warranties, representations or other terms which may apply to our sites or any content on them, whether express or implied.

We will not be liable to any user for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with:

• Use of, or inability to use, our site; or
• Use of or reliance on any content displayed on our site.

If you are a business user, please note that in particular, we will not be liable for any loss of profits, revenues or anticipated savings (in each case whether direct or indirect), trading losses, or for any consequential, punitive, special or indirect loss or damages whatsoever (including, without limitation, damages for business interruption, loss of business, or other pecuniary loss) arising out of the use of or inability to use our site, even if we have been advised of the possibility of such damages.

We will not be liable for any loss or damage caused by a virus, distributed denial-of-service attack, or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our site or to your downloading of any content on it, or on any website linked to it. We assume no responsibility for the content of websites linked on our site. Such links should not be interpreted as endorsement by us of those linked websites. We will not be liable for any loss or damage that may arise from your use of them.

Malware

We do not guarantee that our site will be secure or free from bugs or malware. You are responsible for configuring your information technology, computer programs and platform in order to access our site. You should use your own malware protection software.

Third Party Links and Resources in Our Sites

Where our site contains links to other sites and resources provided by third parties, these links are provided for your information only. We have no control over the content of those sites or resources.

Applicable Law

These terms of use, their subject matter and formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England and Wales.