This privacy notice sets out how we look after your personal data and tells you about your privacy rights and how the law protects you. Personal data is any information about you from which you can be identified. It does not include data where your identity has been removed.

This privacy notice applies when you have provided your personal data to us yourself or someone else has provided your personal data to us.

Please read this privacy notice in full, so that you understand how your personal data is used by us.

1. WHO WE ARE, WHO TO CONTACT AND IMPORTANT INFORMATION 2. PERSONAL DATA WE COLLECT ABOUT YOU 3. HOW WE COLLECT YOUR PERSONAL DATA 4. HOW WE USE YOUR PERSONAL DATA 5. DISCLOSING YOUR PERSONAL DATA 6. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA 7. HOW WE KEEP YOUR PERSONAL DATA SECURE 8. HOW LONG WE KEEP YOUR PERSONAL DATA 9. YOUR LEGAL RIGHTS

We may also provide you with other privacy notices on specific occasions when we are collecting or processing personal data about you, to make sure that you are fully aware of how and why we are using your personal data. This privacy notice is in addition to those other notices and is not intended to override them.

1. WHO WE ARE, WHO TO CONTACT AND IMPORTANT INFORMATION

Who we are

GroVentive Ltd. Registered Office: 52 Grosvenor Gardens, 6th Floor, London, SW1W 0AU. Tel: +44 (0)20 8870 3987 company reg: 11692123 who is responsible for your personal data and may be referred to as “COMPANY”, “we”, “us” or “our” in this privacy notice.

Who to contact

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Our full details are:

Full company name: GroVentive Ltd

Name: Bruno Pannetier

Email address: team@groventive.com

Postal address: 52 Grosvenor Gardens London SW1W 0DH United Kingdom

Telephone number: +44 (0)20 8870 3987

Your right to complain

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO). The ICO is the UK supervisory authority 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 notice

We may update this privacy notice from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this notice. We may also notify you of changes to this notice by email or through any messaging system on our site.

This version was last updated on 03/01/2023

Telling us if your personal data changes

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 (for example, if your contact details have changed).

Third-party links

Our 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 or notices. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Children

This website and our service is not intended for children. We do not knowingly collect personal data relating to children.

2. PERSONAL DATA WE COLLECT ABOUT YOU

The types of personal data we collect

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data may include first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data may include postal address, billing address, delivery address, email address and telephone numbers.
• Transaction Data may include details about payments to and from you and other details of products and services you have purchased from us.
• Profile Data: This refers to information included in your personal profile on our website or service and may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details and history;
• Usage Data: This refers to data about your use of our website or services. This data may include IP address, your log in data, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use;
• Marketing and Communications Data may include your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.

We do not collect any Special Categories of Personal Data about you. Special Categories of Personal Data 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 an order for a product or service you have with us but we will notify you if this is the case at the time.

Other people’s personal data

Please do not provide us with any other person’s personal data, unless we ask you to do so.

3. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect personal data from and about you, as follows

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

• register for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey;
• communicate with us (including by telephone); or
• give us some feedback.

Automated technologies or interactions. As you interact with our website or use our services, we may automatically collect Usage 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 Usage Data about you if you visit other websites employing our cookies.]

Use of cookies

Cookies are small files that collect anonymous information about how visitors use our site, which is then used to help improve the site. The information collected includes the number of site visitors, where visitors come to the site from and the pages they visited. For further information visit www.aboutcookies.org

Third parties or publicly available sources. We may receive personal data about you from various third parties (which may include public sources) as set out below:

• Usage Data from the following parties:
  • (a) analytics providers such as google
  • (b) advertising networks based inside or outside of the EU; and
  • (c) search information providers such as google
  • (d) social networks such as LinkedIn, Instagram, and Facebook
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
• Identity and Contact Data from publicly availably sources [such as Companies House and the Electoral Register based inside the EU].

HOW WE USE YOUR PERSONAL DATA

Introduction

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 or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message or where we are required to have your consent by law. You have the right to withdraw consent to marketing at any time.

Purposes for which we will use your personal data

We have set out below, in a table format, 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.

Marketing

What can we do?

We are only allowed to use your personal data to send you marketing messages if:

• you have specifically requested that information from us (such as a request for a brochure or further information), or:
• in respect of unsolicited marketing messages (i.e. marketing information you have not specifically requested), if you have given your consent; or we have a legitimate interest in doing so (which is not overridden by your interests or fundamental rights). Our legitimate interest here is to develop and grow our business and our business network.

Third-party marketing

We will not share your personal data with any company outside of GroVentive Ltd for marketing purposes without your express opt-in consent.

Opting out

You have the right at any time to ask us to stop sending you marketing messages. You can do this by:

• logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences; or
• by following the opt-out links on any marketing message sent to you; or
• by contacting us at any time.

If you opt out of receiving some or all of our marketing, we will retain your Marketing and Communications Data for our records in order to ensure that we know that you have opted out.

If you change your mind after opting out, you can update your choices at any time by contacting us or logging into the website and adjusting your marketing preferences.

COOKIES and Tracking Technologies

Technologies such as: cookies, beacons, tags and scripts are used by GroVentive and our partners, including marketing partners affiliates, or analytics service providers and business process service providers. These technologies are used in analysing trends, administering Our Site, tracking users’ movements around Our Site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We use cookies for to estimate our audience size and usage pattern; to store information about your preferences, and so allow us to customize Our Site according to your individual interests; to speed up your searches; and to recognize you when you return to Our Site. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Site, but your ability to use some features or areas of Our Site may be limited.

Additionally, we use an ad-publishing service to display 3rd party ads on Our Site. When you view or click on an ad a cookie will be set to help better provide advertisements that may be of interest to you on this and other Web sites. You may opt-out of the use of this cookie by visiting the above tracking preference manage

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.

Ownership

GroVentive Ltd is the owner of the goodwill and intellectual property of the GroVentive brand and Marks. GroVentive Ltd (by way of current and future assignment of rights) owns all right, title and interest to (and all Intellectual Property Rights in) this Branded Service Platform and its database (including all Branded Service Data obtained). By registering your details on the GroVentive Ltd platform and agreeing to the terms set out in this policy you therefore consent that your personal data will become an asset of GroVentive Ltd.

4. DISCLOSING YOUR PERSONAL DATA

Disclosing your personal data to others

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Internal Third Parties:

By registering your details on the GroVentive Ltd platform and agreeing to the terms set out in this policy you therefore consent that your personal data will be shared with GroVentive Ltd, and will therefore become an asset of GroVentive Ltd.

Third Parties

• Service providers acting as processors based in the U.K. who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in the U.K. who provide consultancy, banking, legal,insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities [acting as processors or joint controllers] based [in the United Kingdom] [who require reporting of processing activities in certain circumstances].
• Business Development professionals who will only be shared your data with your consent.
• If GroVentive Ltd or substantially all of its assets are acquired by a third party, in which case your personal data held by it will be one of the transferred 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 notice.

Requirements for our third party service providers

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.

Other disclosures we may make

We may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure

Disclosure on our website

Please note that personal data you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5. HOW WE KEEP YOUR PERSONAL DATA SECURE

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 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.

6. HOW LONG WE KEEP YOUR PERSONAL DATA

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal data are [available in our retention policy which you can request from us by contacting us] OR [are set out below]

[Retention periods

We will retain your personal data as follows:

• [personal data category or categories] will be retained for a minimum period of [period] following [data] and for a maximum period of [period], following [date]
• By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for [six] years after they cease being customers for [tax] purposes.]

In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on 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.

Exceptions

In some circumstances you can ask us to delete your data: see Erasure of Data below for further information.

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.

We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another person.

7. YOUR LEGAL RIGHTS

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data. A summary of those rights is set out below.

Your rights

• Access to data: This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Correction of data: 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.
• Erasure of data: This enables you in some circumstances to require 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: This enables you to object to processing of your personal data where we are relying on our legitimate interests (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.
• Restriction of processing: This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Transfer of data: In certain cases you have the right to 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: You may 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.

If you wish to exercise any of the rights set out above, please contact us.

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 may 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 may 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.