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Last revised September 2017

Abacus Digital Advisory Limited ("We") are committed to protecting and respecting your privacy.

This policy (together with our user terms the "User Terms" and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Your security and privacy are of paramount concern to us. If you have any comments or queries in relation to this Privacy Policy please email support@abacus-digital.com . We take our obligations under the Data Protection Act 1998 (the “ Act”) and all related obligations very seriously and have taken steps to ensure compliance with the provisions of thereof.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By Registering and/or continuing to use the Platform you are accepting and consenting to the practices described in this policy.

Definitions used in this privacy policy but not defined shall have the meanings given to them in the User Terms.

1. INFORMATION WE COLLECT FROM YOU

We may collect and process the following data about you:

• Information you give us. This is information about you that you give us by filling in forms on our Platform or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you Register, subscribe to our Service, upload and modify your content or use other social media functions on our site, and when you report a problem with our Platform. The information you give us may include your full name, e-mail address, job title and phone number, financial information relating to you and your organisation and team and reporting structures.
• Information we collect about you. With regard to each of your visits to our Website we will automatically collect the following information:
  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
  • information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for' page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, any phone number used to call our customer service number and any other information you choose to send to us.

• Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share that data internally and combine it with data collected on the Platform. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical and payment services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

2. COOKIES

· Our Website uses cookies to distinguish you from other users of our Website. To enable us to provide the Services and to monitor and improve our Platform and Website, we may at times gather certain information about you, including details of your operating system, browser version, domain name and IP address, the details of any web site you linked from to our site.

· 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.

· 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 use our Website and also allows us to improve our Website. By continuing to use the Website, you are agreeing to our use of cookies.

• 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, or make use of e-billing services.
  • Analytical/performance cookies. They 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 site 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 (for example, your choice of language or region).

• We may use cookies only to store information such as your user name and your session identifiers to enable us to identify whether you are Registered on our Website and, if so, to shortcut your access to our Website. We will only read cookies from your cookie file placed there through your web browser's interaction with our Website. Also, in most circumstances, you can modify the settings of your browser to accept or reject all cookies or as an alternative to be notified when a cookie is set. To view your security settings access the Internet Options within the tools menu in your browser and select the Privacy tab to choose a privacy setting for the Internet zone you are in. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website.

· Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

3. USES MADE OF THE INFORMATION

We use information held about you in the following ways:

• Information you give to us. We will use this information:
  • to provide our Services, including monitoring and responding to content on our Platform;
  • we may use the information to improve our Services;
  • to carry out our obligations arising under our User Terms;
  • to provide you with information about other services we offer that are similar to those that you have already subscribed for;
  • to allow you to modify and personalise your content on our Platform;
  • to monitor the usage, improve and administer out Website and the Services;
  • to enable us to aggregate user profiles and information in order to improve and provide further services to you;
  • to provide you, or permit selected third parties to provide you, with information about services we feel may interest you (unless you have asked us not to do so);
  • to prevent or detect fraud or abuses;
  • in certain cases we may use your email address to send you information on the Service, our other products and services to enable us to comply with our legal and regulatory obligations;
  • to notify you about changes to our Service; and
  • to ensure that content from our Website is presented in the most effective manner for you and for your computer.

• Information we collect about you. We will use this information:
  • to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our Website to ensure that content is presented in the most effective manner for you and for your computer;
  • to allow you to participate in interactive features of our Service, when you choose to do so;
  • as part of our efforts to keep our Website safe and secure; and
  • to make suggestions and recommendations to you about other services that may interest you.

• Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

4. DISCLOSURE OF YOUR INFORMATION

You agree that we have the right to share your personal information with:

• Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.

• Selected third parties including:
  • business partners, suppliers and sub-contractors for the performance of any contract we enter into with them;
  • analytics and search engine providers that assist us in the improvement and optimisation of our Website;
  • credit reference agencies for the purpose of assessing your credit score where this is a condition of Registration.
• Except as explicitly stated in this Privacy Policy, we do not disclose to any third party the information provided.
• We will disclose your personal information to third parties:
  • in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
  • if Abacus Digital Advisory Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; or
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Abacus Digital Advisory Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

5. SECURITY

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

6. WHERE WE STORE YOUR PERSONAL DATA

• The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (the "EEA ").
• In order to effectively process credit or debit card transactions it may be necessary for the bank or card-processing agency to verify your personal details for authorisation outside the European Economic Area (EEA).
• It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.
• By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
• By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
• All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
• Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our 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.

7. YOUR RIGHTS

Our Website may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

8. ACCESS TO INFORMATION

• The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request will be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
• If you would like a copy of the information held please contact us at support@abacus-digital.com
• If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

9. CHANGES TO OUR PRIVACY POLICY

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail or when you next log onto the Platform. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the Services.

10. CONTACT

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to support@abacus-digital.com