1) Summary

This Notice is issued by CBI Project solutions on behalf of itself, its subsidiaries and its affiliates (together, “CBI”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact, including but not limited to customers, visitors to our Sites, visitors to our offices and other users of our services (together, “you”). Defined terms used in this Notice are explained in Section (13) below. For the purposes of this Notice, CBI is the Controller. Contact details are provided in Section (15) below. This Notice may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Notice carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Notice.

2) Collection of data

We may collect Personal Data about you from the following sources: • Data you provide: We may obtain your Personal Data when you provide it to us (e.g., where you contact us via email or telephone, apply for a position with CBI or provide your details on our office visitor log). • Relationship data: We may collect or obtain your Personal Data in the ordinary course of our relationship with you (e.g., we provide a service to you or to your employer, or you visit our offices). • Data you make public: We may collect or obtain your Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media or business networking profile(s)). • Registration details: We may collect or obtain your Personal Data when you use, or register to use, any of our Sites or services.

3) Creation of personal data

• We may also create Personal Data about you, such as records of your interactions with us, our clients.

4) Categories of pesonal data we collect

We may process the following categories of Personal Data about you:

• Personal details: given name(s); preferred name; and photograph (if provided). • Demographic information: date of birth; salutation; title; and language preferences. • Contact details: address; telephone number; email address; and details of your public business networking profile(s) or online biographies. • Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent). • Employer details: where you interact with us in your capacity as an employee, the name, address, telephone number and email address of your employer, to the extent relevant. • Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms

In Processing your Personal Data in connection with the purposes set out in this Notice, we may rely on one or more of the following legal bases, depending on the circumstances:

• Consent: We may Process your Personal Data where we have obtained your prior, express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way); • Contractual necessity: We may Process your Personal Data where the Processing is necessary in connection with any contract that you may enter into with us (for instance if you are a CBI client); • Compliance with applicable law: We may Process your Personal Data where the Processing is required by applicable law or fulfilling our health and safety obligations to employees); • Vital interests: We may Process your Personal Data where the Processing is necessary to protect the vital interests of any individual; or • Legitimate interests: We may Process your Personal Data where we have a legitimate interest in the Processing. The balancing test we have conducted in each case is as follows: • we have ensured that the Processing is lawful, proportionate, and conducted in accordance with the terms of this Notice; • we have ensured that we have a legitimate business need to perform the Processing; and • we have ensured that there is no material likelihood of any adverse impact on your interests, fundamental rights, or freedoms, as a result of the Processing.

6) Sensitive personal data

Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations or fulfilling our health and safety obligations to employees); • Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (including the prevention of fraud); • Establishment, exercise or defence of legal rights: We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal rights; or • Consent: We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Data (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way). • If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, including ensuring that one of the legal bases set out above is available to us with respect to the Processing of those Sensitive Personal Data.

7) Purpose for which me may process your personal data

We may process your personal data for the following purposes, subject to applicable law: • Provision of services: providing our Sites or services; providing services on request; and communicating with you in relation to those services. • Communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) information in which you may be interested (e.g., upcoming CBI events, new product offerings, information relevant to you as a CBI client), subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required. • Communications and IT operations: management of our communications systems; operation of IT security systems; and IT security audits. • Surveys: engaging with you for the purposes of obtaining your views on our services. • Investigations: detecting, investigating and preventing breaches of policy, fraud, and violations of law, in accordance with applicable law. • Legal proceedings: establishing, exercising and defending legal rights. • Legal compliance: compliance with our legal and regulatory obligations under applicable law or fulfilling our health and safety obligations to employees). • Recruitment and job applications: recruitment activities; advertising of positions; interview activities; analysis of suitability for the relevant position; records of hiring decisions; offer details; and acceptance details.

8) Data security

• We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law. • Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the

9) Data accuracy

We take every reasonable step to ensure that: • your Personal Data that we Process are accurate and, where necessary, kept up to date; and • any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay. • From time to time we may ask you to confirm the accuracy of your Personal Data.

10) Data minimisation

• We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Notice.

11) Data retention

• We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows: • (A) we will retain copies of your Personal Data in a form that permits identification only for as long as: • (Ai) we maintain an ongoing relationship with you or you are lawfully included in our mailing list and have not unsubscribed); • (Aii) (6) years from your most recent interaction with any CBI client; or • (Aiii) your Personal Data are necessary in connection with the lawful purposes set out in this Notice, for which we have a valid legal basis (e.g., where we have a legitimate interest in processing your data for the purposes of operating our business and fulfilling our obligations under a contract), plus: • (B) the duration of: o (Bi)any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data may be relevant); and o (Bii)an additional two (2) month period following the end of such applicable limitation period (so that, if a person bring a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim), o and: • (C) in addition, if any relevant legal claims are brought, we may continue to Process your Personal Data for such additional periods as are necessary in connection with that claim • During the periods noted in paragraphs (B)(i) and (B)(ii) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law. • Once the periods in paragraphs (A), (B) and (C) above, each to the extent applicable, have concluded, we will either: o permanently delete or destroy the relevant Personal Data; or o anonymize the relevant Personal Data.

Subject to applicable law, you may have a number of rights regarding the Processing of your Relevant Personal Data, including: • the right not to provide your Personal Data to us (however, please note that we may be unable to provide you with the full benefit of our Sites, or our services, if you do not provide us with your Personal Data – e.g., we may not be able to process your orders without the necessary details); • the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data; • the right to request rectification of any inaccuracies in your Relevant Personal Data; • the right to request, on legitimate grounds: • erasure of your Relevant Personal Data; or • restriction of Processing of your Relevant Personal Data; • the right to object, on legitimate grounds, to the Processing of your Relevant Personal Data by us or on our behalf; • the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable; • where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and • the right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority (in particular, the Data Protection Authority of the EU Member State in which you live, or in which you work, or in which the alleged infringement occurred, each if applicable). • This does not affect your statutory rights. • To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Notice, or about our Processing of your Personal Data, please use the contact details provided in Section (R) below. Please note that: • we may require proof of your identity before we can give effect to these rights; and • where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take

13) Terms of use

• All use of our Sites, or our services is subject to our terms of use. We recommend that you review our Terms of Use regularly, in order to review any changes we might make from time to time

14) Direct marketing

• We may Process your Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding services that may be of interest to you. If we provide services to you, we may send information to you regarding our services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law. • You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of any services you have requested.

15) Contact details

Compliance team CBI Project Solutions Limited 8 Gordon Road, Romford, Essex, RM6 6DD

Info@cbiprojectsolutions.com