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CALEDONIA INVESTMENTS PLC

PRIVACY AND COOKIES POLICY

This website (the “Site”) is operated and provided by Caledonia Investments plc having its registered office at Cayzer House, 30 Buckingham Gate, London SW1E 6NN.

References to “Caledonia”, “we”, “us” or “our” are references to Caledonia Investments plc and its consolidated group entities.

It is important to us that we protect the privacy of personal information and for you to know what type of information we collect and how we treat information we may receive from you. This policy applies to personal information held about website users.  A separate policy which applies to personal information held about business and prospective business contacts, suppliers and prospective suppliers, individual associated with our investments and prospective investments and all other persons about whom we hold information about is available on request.

The types of information we collect from you

We may collect and store the following types of personal information about you when you use the Site or correspond with us (for example, by email) for any reason, or which we may collect for the purpose of our business activities. This includes information you provide when registering for our email news alert service. The information given to, or collected by, us may include:

The personal data we collect will not include so called ‘sensitive’ or ‘special categories’ of personal data, such as details about your health or ethnic origin.

Automated collection of information

Each time you use the Site, we may automatically collect the following types of information:

Legal basis for processing

Our processing of your personal information is necessary: (i) for the purposes of legitimate interests pursued by us; and (ii) where required by a legal or regulatory obligation.

Legitimate interests

Our processing of your personal data is necessary for the purposes of legitimate interests pursued by us, namely: (i) collecting user information to provide you with a safe, smooth, efficient and customised experience; (ii) to make sure you receive updated information on Caledonia’s business activities if you sign up to our email news alert service; (iii) to provide the services you have requested and to provide them efficiently; (iv) to ensure that the content on the Site is presented in the most effective manner for you and your device; (v) to allow you to participate in any features on the Site when you choose to do so; (vi) for our own marketing, research and investor relations, (vii) to use data analytics to improve our website, and, (viii) for the efficient running of our business and this website.

Purposes of processing and use of your personal information

We may use your personal information specifically to:

Disclosure of personal information

Except as expressly set out in this Privacy and Cookie Policy we do not share, sell, or lease personal information about you to any third parties for their marketing use.

We may disclose personal information to service information requests, respond to legal requirements, enforce our policies and protect our rights and property. The personal information you provide to us may also be shared with our group companies if this is necessary to fulfil our obligations, respond to your enquiries or for any other related purposes.

We may also provide third party advisers and service providers access to information where they support or provide services to us. We will ensure that if we share information with, or provide access to, third party service providers, any such disclosure or access is at all times in compliance with data protection legislation.

We may also share your personal information with:

How long will we keep your information?

We will only keep the information we collect about you for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject. This will involve us reviewing our files to check that information is accurate, up-to-date and still required.

Your rights

You have a number of rights concerning the way that we use your information.  At any time, you have the right to:

Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with applicable data protection legislation.

Security and storage of your information

Although we maintain physical, electronic and administrative safeguards to protect your personal information from unauthorised or inappropriate access, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your personal information transmitted to us or provided though the Site.

Personal information that you submit may be sent to, and stored on, secure servers owned by or operated for us. If we collect personal information about you through the use of the Site we will only retain that information for as long as is reasonably necessary to fulfil the activity requested, or as may be required by law.

Transferring data outside of the UK and EEA

Your personal information may be transferred to, and stored at, a destination outside the United Kingdom (the “UK”) or the European Economic Area (“EEA“) and may also be processed by staff operating outside the UK and EEA who work for us, or for one of our service providers.

When we, or our permitted third parties, transfer your information outside the UK and EEA, we or they will impose contractual obligations on the recipients of that data to protect your information to the standard required in the UK.   We or they may also require the recipient to subscribe to international frameworks intended to enable secure data sharing.  In the case of transfers by us, we may also transfer your information where: (i) the transfer is to a country deemed by the UK to provide adequate protection of your information; or (ii) where you have consented to the transfer.

Opt-Out

You also have the option of “unsubscribing” from our mailing list for email news alerts and updates at any time, thereby disabling any further such email communication from being sent to you. To unsubscribe just click the “Unsubscribe/Update Account” link. Alternatively, you can send an email to enquiries@caledonia.com  with the word ‘remove’ in the subject line and the email address that you wish to be removed within the email. In addition, each electronic mailing we send you will contain details of how you can unsubscribe.

Automated processing

We do not carry out automated decision-making or profiling in relation to your personal information.

Cookies

Our use of cookies

Caledonia sets and accesses cookies and similar technology on your device to obtain information about how you access and use the Site. This helps us to provide you with a good experience and allows us to improve the Site. Unless you have adjusted your browser settings so that it will refuse cookies, the Site will set cookies when you load and navigate them.

What are cookies?

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a Site. Cookies are then sent back to the originating Site during your browsing session or on each subsequent visit, or to another Site that recognises that cookie. The cookies we set do lots of different jobs, such as to help us to improve the Site and deliver a better and more personalised service, remember your preferences, and generally improve the user experience. You can find more information about cookies at http://www.allaboutcookies.org/.

Cookies can be categorised in accordance with the categories found in the ICC UK cookie guide as set out below:

Cookies can also be categorised in accordance with how long they are saved on your device: “session cookies” are short-term cookies that are only saved on the device’s memory for the duration of a user’s visit to the Site, whereas “persistent cookies” remain saved in the device’s memory for a set period of time, even after the browser session has ended.

Refusing or restricting cookies

You may refuse to accept cookies by adjusting your preferences here or by activating the setting on your browser which allows you to refuse the setting of cookies. The “Help” or “Internet Settings” functions within your browser should tell you how. Alternatively, you may wish to visit http://www.allaboutcookies.org/ which contains detailed information on cookies and how to delete, restrict or block them on a wide variety of browsers. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual.

Please be aware that if you select to refuse or restrict cookies you may be unable to access certain parts of the Site.

Contacting us

If you have any questions about this Privacy and Cookies Policy, please contact us at enquiries@caledonia.com, on +44 20 7802 8080 or alternatively at Caledonia Investments plc, Cayzer House, 30 Buckingham Gate, London SW1E 6NN.

If you have any concerns about our use of your information, you also have the right to make a complaint to the Information Commissioner’s Office, which regulates and supervises the use of personal data in the UK, via their helpline on 0303 123 1113.

Changes to this Policy

We may amend this Privacy and Cookie Policy at any time by posting the amended terms on the Site. All amended terms will automatically take effect immediately on posting. Please check this Privacy and Cookies Policy periodically to inform yourself of any changes. If you do not accept the changes made to this Privacy and Cookies Policy you should immediately stop using the Site.

Version: 30 July 2020