Coinsilium Group Limited is committed to respecting your privacy and complying with applicable laws to ensure that the personal information you give us is kept appropriately secure and processed fairly and lawfully.

This Privacy Notice explains how Coinsilium Group Limited and its group of companies (together referred to in this Privacy Notice as “Coinsilium”, “we”, “us” and “our”), together use personal information about you that we collect, use and otherwise process in connection with your relationship with Coinsilium as a shareholder. Coinsilium will collect and use your personal information as described in this Privacy Notice and as permitted by applicable laws, including in circumstances where: (i) it is necessary to fulfil a contract with you (to carry out our obligations to you as a shareholder); (ii) you have given us your express consent; (iii) it is necessary for one or more legitimate interests pursued by Coinsilium; or (iv) Coinsilium is required to process your personal information in order to comply with a legal obligation to which it is subject.

What personal information we collect and how we use it

Coinsilium collects your personal information when you register as a shareholder and when you interact with us in relation to your shareholding with us. This includes when we receive your personal information from third parties, for example, share registrars and brokers.

We may collect the following information:  your name, title, address, phone number, e-mail address, date of birth, identification documentation such as passport information or national insurance number, bank account details, shareholder records (including shares held, share purchases, share disposals, dividend entitlements and payments, votes, proxy appointments, shareholder options, exercise conditions and exercise dates) and copies of enquiries, complaints and other correspondence and communications with you as a shareholder.

The personal data we collect will be held and processed by Coinsilium for the following purposes:

• to manage your shareholding interest in Coinsilium and our relationship with you as a shareholder, including:
• to allow you to exercise your rights as a shareholder;
• to include you on our register of shareholders and maintain this and keep it up-to-date;
• to make dividend payments;
• to contact you with shareholder-related information, including but not limited to shareholder announcements and information about dividend distributions, reports and meetings, including our Annual General Meeting;
• to provide information to our registrar, so they can manage your shareholding on our behalf;
• it is necessary for one or more of the following legitimate interests pursued by Coinsilium:
• to produce and maintain shareholder records, announcements and communications;
• to review and respond to any enquiries and complaints you submit to us;
• to conduct data analytics studies to review and better understand and monitor shareholder patterns;
• to manage and administer Coinsilium’s business effectively;
• to comply with KYC, AML requirements or similar of our service providers;
• for proper record-keeping purposes relating to Coinsilium ’s business and shareholdings;
• to comply with legal or regulatory requirements.

Sharing your personal data

In certain circumstances, we may share your personal information with selected third-party service providers as permitted by applicable laws or with your consent (if so required by applicable laws), for example, with companies that provide support services to us, including professional advisors, brokers and administration and IT service providers. In each case, we will only provide these companies with the information which they need to carry out their services and they will not be permitted to use the information for other purposes. They will only be allowed to use your information in the way in which we instruct them and as permitted by applicable laws.

Computershare Limited, our registrars, also collects and processes your personal data so that they can manage your shareholding on our behalf. 

In certain circumstances (where required or permitted under applicable laws or with your consent (if so required by applicable laws), we may disclose personal information relating to you to third parties including government bodies and regulators in order to conform to any requirements of law, to comply with any legal or regulatory process, for the purposes of obtaining legal advice, to prevent and detect fraud and/or to protect and defend the rights and property of Coinsilium and other members of the Coinsilium group. 

Overseas transfers of data

We may transfer information that we collect from you to selected service providers who perform functions on our behalf (as described above), based in countries outside of the U.K, Gibraltar and the European Economic Area ("EEA") or your country of residence and this information may be stored and processed in such countries.

Personal information stored in another jurisdiction may be subject to access requests from governments, courts, or law enforcement in that jurisdiction according to its laws. Whether the personal information you provide to Coinsilium is processed by us or our service providers within the U.K., Gibraltar or EEA or outside of it, we will take steps to ensure that your personal information will be afforded the level of protection required of Coinsilium under and in accordance with applicable data protection laws and in accordance with current legally recognised data transfer mechanisms.

Your Rights

You may have the right under applicable laws to ask for details of the personal information that Coinsilium holds about you, to amend, limit or delete your personal information, or ask for a copy of the personal information we hold about you. You can also object to us using your personal information for Coinsilium ’s legitimate interests.

You may also withdraw your consent where Coinsilium relies on consent to process your personal information and you may have a right to have your personal information transferred to a third party or to object to or restrict the processing of your personal information.  In some cases, you may also exercise your right to give instructions on how your personal information should be used after your death.

If you have any questions about the way in which your information is being collected or used or if you would like to exercise any of these rights, please write to Coinsilium by emailing to info@coinsilium.com.  If you remain unhappy with a response you receive from us you can also refer the matter to your data protection supervisory authority (found here).

Retention and deletion of personal information

We will only keep your information as long as you remain a shareholder and for up to 10 years after you cease to be a shareholder, including for the purposes of identifying, issuing or resolving legal claims and for proper record keeping purposes (including to comply with legislative and regulatory requirements).

Once it is no longer required to be retained, your personal information will be deleted or destroyed in a manner that cannot be restored or reproduced.

Security

We take reasonable steps to protect your personal information against unauthorised or accidental access, processing, erasure, loss or use. 

Personal information may be accessed by persons within our organisation, or our third-party service partners, who require such access to carry out the purposes indicated above, or such other purposes as may be permitted or required by applicable laws.