Introduction

HalcyonFT is committed to protecting your privacy. This privacy notice (Privacy Notice) explains how companies in Halcyon Financial Technology, L.P.’s group of companies (together, HalcyonFT or we or our or us) collect and process your personal data, including any data you may provide when you purchase our services or access our website. It also explains how we will store, manage and keep that data safe.

We may update this privacy notice from time to time.

HalcyonFT consists of two companies: Halcyon Financial Technology, L.P our headquarters based in California, USA; and Halcyon Financial Technology Ltd, based in London, UK.

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 as follows:

• Identity Data includes first name, maiden name, last name, job title and organisation name.

• Contact Data includes billing address, personal email address, business email address and telephone numbers.

• Financial Data includes bank account and payment card details held at third party processors, optional and when provided.

• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

• Usage Data includes information about how you use our website and services.

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

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 personal data when you:

  • correspond with us by post, phone, email or otherwise

  • become a client for our services;

  • request that we contact you via the Inquire button on our contact page

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

• Third parties. We may receive personal data about you from various third parties as set out below:

  • Identity, Contact, Financial and Transaction Data from providers of payment and delivery the Services that you use to pay us.

  • Technical Data from analytics providers such as Google Analytics.

How we use your Personal Data

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.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service purchase.

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 services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please visit www.halcyonft.com/cookie-policy.

Disclosures of your Personal Data

We may share your personal data with the following third-parties for the purposes set out in the table above:

• Third party service providers - we use some third-party providers to help us run our business such as service providers who provide IT and system administration systems.

• Professional advisers including lawyers, bankers, auditors and insurers based in the provide consultancy, banking, legal, insurance and accounting services.

• Tax authorities who require reporting of processing activities in certain circumstances.

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our 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 policy.

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.

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 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.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we may have to keep basic information about our customers after they cease being customers for tax and accounting purposes.

For our UK-based clients, in some circumstances you can ask us to delete your data: please see your legal rights below for further information.

UK requirements - This section only applies if United Kingdom (UK) data protection law applies to the processing of your information

For our UK-based clients, in addition to the personal data processing detailed earlier in this Privacy Notice, please see below further information and your rights in accordance with UK data protection laws.

Data controller

For UK-based clients, Halcyon Financial Technology Ltd (71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ, company number 15054998) is the data controller where applicable. This mostly applies to our own marketing efforts, our own website, and other ways of collecting personal data as per this Privacy Notice.

Where we are processing personal data in relation to a client’s use of our services, we will be the data processor under our contract acting on the client’s instructions as the data controller.

Legal bases of processing

We will only use your personal data when UK data protection law allows us to. Most commonly, we process your personal data for the purposes described in this Privacy Notice, based on the following legal grounds:

• Where we need to perform the contract we are about to enter into or have entered into with you (such as providing services to 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. For example, improving our services to meet the needs of our clients.

• Where we need to comply with a legal obligation. For example, legal obligations sometimes require us to retain certain information for purposes like tax and accounting purposes.

International Transfers

In order to provide our services, we may need to transfer your personal information to locations outside the United Kingdom for the purposes set out in this Privacy Notice. This may entail a transfer of your information from either a location within the European Economic Area (the “EEA”) or the UK to outside the EEA/UK, or from outside the EEA to a location within the EEA/UK.

The level of information protection in countries outside the EEA/UK may be less than that offered within the EEA/UK. Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws. UK standard contractual clauses are in place between the HalyconFT group of companies that share and process personal data. Please contact us using the details in the ‘How to contact us’ section below to request a copy of these clauses. Where our third-party service providers process personal data outside the EEA/UK in the course of providing services to us, our written agreement with them will include appropriate measures, usually standard contractual clauses.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where you have chosen a password which enables you to access certain parts of our website, 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 website; 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.

Your Legal Rights

If UK data protection law applies to the processing of your information, under certain circumstances, you have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. 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.

• Request erasure of your personal data. This enables you to ask 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.

• Object to processing of your personal data where we are relying on a legitimate interest (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.

• 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:

• If you want us to establish the data's accuracy.

• Where our use of the data is unlawful but you do not want us to erase it.

• 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.

• 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 which you initially provided consent for us to use or where we used the information to perform a contract with you.

• 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 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 could 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 could 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.

Complaints

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), 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.

How to Contact us

We hope this Privacy Notice has been helpful in terms of how we use your personal data and your rights in relation to such personal data. If you have any questions, please contact us:

• Email us at legal@halcyonft.com.

• Write to us at 1 Blackfield Drive #252, Tiburon, CA 94920 or 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ.