WEALTH RECOVERY SOLICITORS WEBSITE PRIVACY POLICY

INTRODUCTION

Welcome to Global Securities Limited’s privacy notice. Global Securities Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website(regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. Please use the Glossary to understand the meaning of some of the termsused in this privacy notice.

IMPORTANT INFORMATION AND WHO WE ARE PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Global Securities Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or service. This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER

Global Securities Limited is the controller and responsible for your personal data (collectively referred to as ”Global Securities Limited”, “we”, “us” or “our” in this privacy notice). We have appointed a data privacy manager who is responsible foroverseeing 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 data privacy manager using the details set out below.

CONTACT DETAILS

Our full details are:

Full name of legal entity: Global Securities Limited

Name of data privacy manager: Josh Chinn

Email address: josh.chinn@gblsecurities.com

Postal address: Global Securities Limited 1 St James’s Square, Florida, 33137 Telephone number: +1 (347) 201-8691

You have the right to make a complaint at any time to the Information Commissioner’s Office(ICO), the USA 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 soplease contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF 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. THIRD PARTY LINKS This website may include links to third-party websites, plug-ins andapplications. Clicking on those links or enabling those connections may allow third parties tocollect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you toread the privacy notice of every website you visit.

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier,marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephonenumbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details ofproducts and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type andversion, time zone setting and location, browser plug-in types and versions, operatingsystem and platform and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you,your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketingfrom us and our third parties and your communication preferences. We may also collect, useand 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 personaldata in law as this data does not directly or indirectly reveal your identity. For example, wemay aggregate your Usage Data to calculate the percentage of users accessing a specificwebsite feature. However, if we combine or connect Aggregated Data with your personaldata so that it can directly or indirectly identify you, we treat the combined data as personaldata which will be used in accordance with this privacy notice. We do not collect any Special Categories of Personal Data about you (this 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). Nordo 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 a product or service you have with us butwe will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling informs or by corresponding with us by post, phone, email or otherwise. This includes personaldata you provide when you:
  • apply for our products or services;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.
  • Automated technologies or interactions.
  • As you interact with our website, we may automatically collect Technical Data about yourequipment, browsing actions and patterns. We collect this personal data by using cookies,and other similar technologies
  • Third parties or publicly available sources. We may receive personal data about you fromvarious third parties and public sources as set out below:
  • Technical Data from the following parties: (a) analytics providers such as Google basedoutside the EU; (b) advertising networks; and (c) search information providers.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the EU.
  • Identity and Contact Data from data brokers or aggregators based inside or outside the EU.
  • Identity and Contact Data from publicly availably sources such as Companies House andthe Electoral Register based inside the EU.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will useyour personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into withyou.

  • Where it is necessary for our legitimate interests (or those of a third party) and yourinterests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation. Generally we do not relyon consent as a legal basis for processing your personal data other than in relation tosending third party direct marketing communications to you via email or text message. Youhave the right to withdraw consent to marketing at any time by contacting us.

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 yourpersonal data for more than one lawful ground depending on the specific purpose for whichwe 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.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularlyaround marketing and advertising.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view onwhat we think you may want or need, or what may be of interest to you. This is how wedecide which products, services and offers may be relevant for you (we call this marketing).You may receive marketing communications from us if you have requested information fromus or purchased goods or services from us or if you provided us with your details when youentered a competition or registered for a promotion and, in each case, you have not optedout of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with anycompany outside Global Securities Limited for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time bycontacting us at any time. Where you opt out of receiving these marketing messages, thiswill not apply to personal data provided to us as a result of a product/service purchase,warranty registration, product/service experience or other transactions.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you whenwebsites set or access cookies. If you disable or refuse cookies, please note that some partsof this website may become inaccessible or not function properly. For more informationabout the cookies we use, please see our Cookie Policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless wereasonably consider that we need to use it for another reason and that reason is compatiblewith the original purpose. If you wish to get an explanation as to how the processing for thenew purpose is compatible with the original purpose, please contact us. If we need to useyour 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 datawithout your knowledge or consent, in compliance with the above rules, where this isrequired or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business orour assets. Alternatively, we may seek to acquire other businesses or merge with them. If achange happens to our business, then the new owners may use your personal data in thesame way as set out in this privacy notice. We require all third parties to respect the securityof 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 permitthem to process your personal data for specified purposes and in accordance with ourinstructions.

INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA)

DATA SECURITY

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 personaldata on our instructions and they are subject to a duty of confidentiality. We have put inplace procedures to deal with any suspected personal data breach and will notify you andany applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

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. 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. 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. In some circumstances you can ask us to delete your data.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.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data which include the following (see Glossary)

  • access to your personal data.
  • correction of your personal data.
  • erasure of your personal data.
  • processing of your personal data.
  • restriction of processing your personal data.
  • transfer of your personal data.
  • Right to withdraw 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 andensure your right to access your personal data (or to exercise any of your other rights). Thisis a security measure to ensure that personal data is not disclosed to any person who has noright to receive it. We may also contact you to ask you for further information in relation toyour 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 uslonger than a month if your request is particularly complex or you have made a number ofrequests. In this case, we will notify you and keep you updated.

GLOSSARY LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing ourbusiness to enable us to give you the best service/product and the best and most secureexperience. We make sure we consider and balance any potential impact on you (bothpositive and negative) and your rights before we process your personal data for ourlegitimate interests. We do not use your personal data for activities where our interests areoverridden by the impact on you (unless we have your consent or are otherwise required orpermitted to by law). You can obtain further information about how we assess our legitimateinterests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for theperformance of a contract to which you are a party or to take steps at your request beforeentering into such a contract. Comply with a legal or regulatory obligation meansprocessing your personal data where it is necessary for compliance with a legal or regulatoryobligation that we are subject to.

THIRD PARTIES INTERNAL THIRD PARTIES

Other companies and individuals within Global Securities Limited who are based the United States and provide IT and system administration services and undertake leadership reporting.

EXTERNAL THIRD PARTIES

  • Service providers including our website provider based in the United States whichprovide IT and system administration services.
  • Professional advisers including recovery experts, bankers, auditors and insurers based in theUnited States who provide consultancy, banking, legal, insurance and accountingservices.
  • HM Revenue & Customs, regulators and other authorities based in the United Stateswho require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to: Request access to your personal data (commonly known as a “datasubject access request”). This enables you to receive a copy of the personal data we holdabout you and to check that we are lawfully processing it. Request correction of thepersonal data that we hold about you. This enables you to have any incomplete orinaccurate data we hold about you corrected, though we may need to verify the accuracy ofthe new data you provide to us. Request erasure of your personal data. This enables you toask us to delete or remove personal data where there is no good reason for us continuing toprocess 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 arerequired to erase your personal data to comply with local law. Note, however, that we maynot always be able to comply with your request of erasure for specific legal reasons whichwill be notified to you, if applicable, at the time of your request. Object to processing of yourpersonal data where we are relying on a legitimate interest (or those of a third party) andthere is something about your particular situation which makes you want to object toprocessing 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 directmarketing purposes. In some cases, we may demonstrate that we have compellinglegitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal data. 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. 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 whichyou initially provided consent for us to use or where we used the information to perform acontract with you. Withdraw consent at any time where we are relying on consent toprocess your personal data. However, this will not affect the lawfulness of any processingcarried out before you withdraw your consent. If you withdraw your consent, we may not beable to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.Global Securities Limited 1 St James’s Square, Florida, 33137