JANUARY 2024 REVISION

contents.

1. WHAT IS THE PURPOSE OF THIS DOCUMENT?
2. DATA PROTECTION PRINCIPLES
3. THE KIND OF INFORMATION WE HOLD ABOUT YOU
4. HOW IS YOUR PERSONAL INFORMATION COLLECTED?
5. HOW WE WILL USE INFORMATION ABOUT YOU
6. HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION
7.INFORMATION ABOUT CRIMINAL CONVICTIONS
8. AUTOMATED DECISION-MAKING
9. DATA SHARING
10. DATA SECURITY
11. DATA RETENTION
12. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
13.RIGHT TO WITHDRAW CONSENT
14. DATA PROTECTION OFFICER
15. CHANGES TO THIS PRIVACY NOTICE

Key points:

Graft Ltd is committed to protecting the privacy and security of your personal information. Thisprivacy notice describes how we collect and use personal information about you during and afteryour working relationship with us, in accordance with the UK General Data Protection Regulation. Itapplies to all employees, workers and freelance contractors, and in part to interns and volunteers.

In more detail:

Graft Ltd is a “controller” (also called a “data controller”). This means that we are responsible fordeciding how we hold and use personal information about you. We are required under dataprotection legislation to notify you of the information contained in this privacy notice.

This notice applies to current and former employees, workers and freelance contractors. It will alsoapply to interns and volunteers, to the extent that data of the types described in this notice isprocessed by Graft Ltd. in relation to such individuals.

This notice does not form part of any contract of employment or other contract between us. We mayupdate this notice at any time, but if we do so, we will provide you with an updated copy of thisnotice as soon as reasonably practicable.

It is important that you read and retain this notice, together with any other privacy notice we mayprovide on specific occasions when we are collecting or processing personal information about you,so that you are aware of how and why we are using such information and what your rights are underthe data protection legislation.

DATA PROTECTION PRINCIPLES

We will comply with data protection law. This says that the personal information we hold about youmust be:

Used lawfully, fairly and in a transparent way.

Collected only for valid purposes that we have clearly explained to you and not used in any way thatis incompatible with those purposes.

Relevant to the purposes we have told you about and limited only to those purposes.

Accurate and kept up to date.

Kept only as long as necessary for the purposes we have told you about. Kept securely.

THE KIND OF INFORMATION WE HOLD ABOUT YOU

Key points:

Personal data, or personal information, means any information about an individual from which thatperson can be identified. It does not include data where the identity has been removed (anonymousdata).

There are “special categories” of more sensitive personal data which require a higher level ofprotection, such as information about a person’s health or sexual orientation. Information aboutcriminal convictions also warrants this higher level of protection.

In more details:

We may collect, store, and use the following categories of personal information about you: Personalcontact details such as name, title, addresses, telephone numbers, and personal email addresses.

● Date of birth.

● Gender.

● Marital status and dependents.

● Next of kin and emergency contact information.

● National Insurance number.

● Bank account details, payroll records and tax status information.

● Salary, annual leave, pension and benefits information.

● Start date and, if different, the date of your continuous employment/engagement.

● Leaving date and your reason for leaving.

● Location of employment or workplace.

● Copy of driving licence.

● Recruitment information (including copies of right to work documentation, references andother information included in a CV or cover letter or as part of the application process).

● Employment records (including job titles, work history, working hours, training records andprofessional memberships). Compensation history.

● Performance information.

● Disciplinary and grievance information.

● CCTV footage and other information obtained through electronic means such as swipe cardrecords.

● Information about your use of our information and communications systems.

● Photographs.

● Passport, visa, ‘right to work’ documents, and/or sponsorship papers.

● Results of HMRC employment status check, details of your interest in and connection withany intermediary through which your services are supplied.

● We may also collect, store and use the following “special categories” of more sensitivepersonnel.

● information:

● Information about your race or ethnicity, religious beliefs, sexual orientation and politicalopinions.

● Trade union membership.

● Information about your health, including any medical condition, health and sickness records,

● including: where you leave employment and under any share plan operated by a groupcompany the

● the reason for leaving is determined to be ill-health, injury or disability, the records relatingto that decision.

● details of any absences (other than holidays) from work including time on statutory parentalleave and sick leave; and where you leave employment and the reason for leaving is relatedto your health, information about that condition needed for pensions and permanent healthinsurance purposes.

● Genetic information and biometric data.

● Information about criminal convictions and offences.

HOW IS YOUR PERSONAL INFORMATION COLLECTED?

We collect personal information about employees, workers and contractors through the applicationand recruitment process, either directly from candidates or sometimes from an employmentagency/business or umbrella company, from online sources (such as LinkedIn), from CV databases, orfrom a background check provider. We may sometimes collect additional information from thirdparties including former employers/engagers, referees, business partners, sub-contractors intechnical, payment and delivery services, credit reference agencies or other background checkagencies. We may also collect personal information from the trustees or managers of pensionarrangements operated by a group company. We will collect additional personal information duringjob-related activities throughout the period of you working for us.

HOW WE WILL USE INFORMATION ABOUT YOU

Key points:

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

Where we need to perform the contract, we have entered with you, or to take steps to enter contractwith you or under which you will perform services.

Where we need to comply with a legal obligation.

Where it is necessary for our legitimate interests (or those of a third party) and your interests andfundamental rights do not override those interests.

Where we are legally permitted to do so, and we have your informed or (in certain circumstances)explicit consent. We may also use your personal information in the following situations, which arelikely to be rare: Where we need to protect your interests (or someone else’s interests).

Where it is needed in the public interest or for official purposes.

Situations in which we will use your personal information:

We need all the categories of information in the list above (see the kind of information we holdabout you) primarily to allow us to perform our contract with you and to enable us to comply withlegal obligations. In some cases, we may use your personal information to pursue legitimate interestsof our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below:

● Deciding about your recruitment or appointment or engagement.

● Seeking, placing you in, and managing your assignments.

● Determining the terms on which you work for us.

● Checking you are legally entitled to work in the UK.

● Paying you and, if you are an employee or deemed employee for tax purposes, or if weare otherwise legally required to do so, deducting tax and National Insurancecontributions (‘NICs’).

● Providing benefits to you, including (where applicable):

● Inviting you to participate in any share plans operated by a group company.

● Granting awards under any share plans operated by a group company.

● Administering your participation in any share plans operated by a group company,including communicating with you about your participation and collecting any tax andNICs due on any share awards.

● Enrolling you in a pension arrangement in accordance with our statutory automaticenrolment duties.

● Liaising with the trustees or managers of a pension arrangement operated by a groupcompany, your pension provider and any other provider of employee benefits.Administering the contract, we have entered with you.

● Business operation, management, and planning, including accounting and auditing.

● Conducting performance reviews, managing performance and determining performance requirements.

● Making decisions about salary reviews and compensation.

● Assessing qualifications for a particular job or task, including decisions aboutpromotions.

● Gathering evidence for possible grievance or disciplinary hearings.

● Making decisions about your continued employment or engagement.

● Planning for the termination of our working relationship.

● Education, training and development requirements.

● Dealing with legal disputes and insurance claims involving you, or other employees, workers and contractors, including accidents at work. Ascertaining your fitness to work.

● Managing sickness absence.

● Complying with health and safety obligations.

● To prevent fraud.

● To monitor your use of our information and communication systems to ensurecompliance with our IT policies.

● To ensure network and information security, including preventing unauthorised access toour computer and electronic communications systems and preventing malicioussoftware distribution.

● To conduct data analytics studies to review and better understand employee retentionand attrition rates. To demonstrate our own compliance with legal obligations, to thirdparties who themselves have legitimate interests in satisfying themselves as to ourcompliance.

● To manage and maintain any applicable insurance policies.

● Equal opportunities monitoring.

● Some of the above grounds for processing will overlap and there may be several groundswhich justify our use of your personal information.

If you fail to provide certain information when requested, we may not be able to perform thecontract we have entered with you (such as paying you or providing benefit), or we may beprevented from complying with our legal obligations (such as to ensure the health and safety of ourworkers).

We will only use your personal information for the purposes for which we collected it, unless wereasonably consider that we need to use it for another reason and that reason is compatible with theoriginal purpose. If we need to use your personal information for an unrelated purpose, we willnotify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, incompliance with the above rules, where this is required or permitted by law.

HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION

Key points:

“Special categories” of particularly sensitive personal information require higher levels of protection.We need to have further justification for collecting, storing and using this type of personalinformation. We may process special categories of personal information in the followingcircumstances:

● In limited circumstances, with your explicit written consent.

● Where we need to carry out our legal obligations and in line with our data protection policy.

● Where it is needed in the public interest, such as for equal opportunities monitoring or inrelation to our occupational pension scheme, and in line with our data protection policy.

● Where it is needed to assess your working capacity on health grounds, subject toappropriate confidentiality safeguards.

Less commonly, we may process this type of information where it is needed in relation to legal claimsor where it is needed to protect your interests (or someone else’s interests) and you are not capableof giving your consent, or where you have already made the information public. We may also processsuch information about employees, workers and contractors or former employees, workers andcontractors during legitimate business activities with the appropriate safeguards.

Our obligations:

o We may be required to use your particularly sensitive personal information in thefollowing ways:

o We may use information relating to leaves of absence, which may include sicknessabsence or family related leaves, to comply with employment and other laws.

o We may use information about your physical or mental health, or disability status, toensure your health and safety in the workplace and to assess your fitness to work, toprovide appropriate.
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● workplace adjustments, to monitor and manage sickness absence and to administer benefits, including statutory maternity pay, statutory sick pay, pensions and permanent health insurance.
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o If you are employed and if you leave employment, and under any share planoperated by a group.

● company the reason for leaving is determined to be ill-health, injury or disability, we will useinformation about your physical or mental health, or disability status in reaching a decisionabout

● your entitlements under the share plan.

▪ If you apply for an ill-health pension under a pension arrangement operatedby a group company, we will use information about your physical or mentalhealth in reaching a decision about your entitlement.

o We may use information about your race or national or ethnic origin, religious,philosophical or moral beliefs, or your sexual life or sexual orientation, to ensuremeaningful equal opportunity monitoring and reporting.

o We may use trade union membership information to pay trade union premiums,register the status of a protected employee and to comply with employment lawobligations.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordancewith our written policy to carry out our legal obligations or exercise specific rights in the field ofemployment law. In limited circumstances, we may approach you for your written consent to allowus to process certain particularly sensitive data. If we do so, we will provide you with full details ofthe information that we would like and the reason we need it, so that you can carefully considerwhether you wish to consent. You should be aware that it is not a condition of your contract with usthat you agree to any request for consent from us.

INFORMATION ABOUT CRIMINAL CONVICTIONS

Key points:

We may only use information relating to criminal convictions where the law allows us to do so. Thiswill usually be where such processing is necessary to carry out our obligations and provided, we doso in line with our data protection policy.

Less commonly, we may use information relating to criminal convictions where it is necessary inrelation to legal claims, where it is necessary to protect your interests (or someone else’s interests)and you are not capable of giving your consent, or where you have already made the informationpublic.

We may also process such information about employees, workers and contractors or formeremployees, workers and contractors during legitimate business activities with the appropriatesafeguards. In more detail:

● We envisage that we may hold information about criminal convictions.

● We will only collect information about criminal convictions if it is appropriate given thenature of the role and where we are legally able to do so. Where appropriate, we will collectinformation about criminal convictions as part of the recruitment process or we may benotified of such information directly by you during you working for us. We will useinformation about criminal convictions and offences in the following ways: To ensure you aresuitable for assignments for which you are considered.

AUTOMATED DECISION-MAKING

Key points:

Automated decision-making takes place when an electronic system uses personal information todecide without human intervention. We are allowed to use automated decision-making in thefollowing circumstances: Where we have notified you of the decision and given you 21 days torequest reconsideration.

Where it is necessary to perform the contract with you and appropriate measures are in place tosafeguard your rights. In limited circumstances, with your explicit written consent and whereappropriate measures are in place to safeguard your rights.

If we make an automated decision based on any particularly sensitive personal information, we musthave either your explicit written consent or it must be justified in the public interest, and we mustalso put in place appropriate measures to safeguard your rights. In more detail:

You will not be subject to decisions that will have a significant impact on you based solely onautomated decision-making, unless we have lawful basis for doing so and we have notified you.

We do not envisage that any decisions will be taken about you using automated means, however wewill notify you in writing if this position changes.

Data sharing

Key points:

We may have to share your data with third parties, including third-party service providers and otherentities in the group. We require third parties to respect the security of your data and to treat it inaccordance with the law. We may transfer your personal information outside the UK. If we do, youcan expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We may share your personal information with third parties where required by law, to seek, place youin, or manage your assignments, where it is necessary to administer the working relationship withyou, to demonstrate our own compliance with legal obligations, to third parties who themselveshave legitimate interests in satisfying themselves as to our compliance, to manage and maintain anyapplicable insurance policies, where we have your informed consent, or where we have anotherlegitimate interest in doing so.

Which third-party service providers process my personal information?

” Third parties” includes third-party service providers (including contractors and designated agents)and other entities within our group. The following activities are carried out by third-party serviceproviders: Payroll, pension administration, benefits provision and administration, IT services.

We will share personal data relating to your participation in any share plans operated by a groupcompany with third party administrators, nominees, registrars and trustees for the purposes ofadministering the share plans. The following third-party service providers process personal dataabout you for this purpose:

DNS Accountants -Business partner -Payroll processing.

Smart Pension -Chosen provider for processing employee’s workplace pension scheme.

We will share personal data regarding your participation in any pension arrangement operated by agroup company with the trustees or scheme managers of the arrangement in connection with theadministration of the arrangements.

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group are required to take appropriatesecurity measures to protect your personal information in line with our policies. We do not allow ourthird-party service providers to use your personal data for their own purposes. We only permit themto process your personal data for specified purposes and in accordance with our instructions.

When might you share my personal information with other entities in the group?

We will share your personal information with other entities in our group as part of our regularreporting activities on company performance, in the context of a business reorganisation or grouprestructuring exercise, for system maintenance support and hosting of data. We will share personaldata relating to your participation in any share plans and pension arrangements operated by a groupcompany with other entities in the group for the purposes of administering the share plans.

What about other third parties?

We may share your personal information with other third parties, for example in the context of thepossible sale or restructuring of the business. In this situation we will, so far as possible, shareanonymised data with the other parties before the transaction completes. Once the transaction iscompleted, we will share your personal data with the other parties if and to the extent requiredunder the terms of the transaction.

We may also need to share your personal information with a regulator or to otherwise comply withthe law. This may include making returns to HMRC, disclosures to stock exchange regulators(including a Regulatory News Service) and disclosures to shareholders such as directors’remuneration reporting requirements.

Key points:

We have put in place measures to protect the security of your information. Details of these measuresare available upon request.

Third parties will only process your personal information on our instructions and where they haveagreed to treat the information confidentially and to keep it secure.

In more details:

We have put in place appropriate security measures to prevent your personal information from beingaccidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limitaccess to your personal information to those employees, agents, contractors and other third partieswho have business needs to know. They will only process your personal information on ourinstructions, and they are subject to the duty of confidentiality. Details of these measures may beobtained from the Data Compliance Manager.

We have put in place procedures to deal with any suspected data security breach and will notify youand any applicable regulator of suspected breach where we are legally required to do so.

DATA retention

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes wecollected it for, including for the purposes of satisfying any legal, accounting, or reportingrequirements. To determine the appropriate retention period for personal data, we consider theamount, nature, and sensitivity of the personal data, the potential risk of harm from unauthoriseduse or disclosure of your personal data, the purposes for which we process your personal data andwhether we can achieve those purposes through other means, and the applicable legalrequirements. Where we may be an employment business, we are required by law to retaincandidates’ personal data for at least one year after we last provided services to them.

In some circumstances we may anonymise your personal information so that it can no longer beassociated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and in duecourse securely destroy your personal information in accordance with our data retention policy ORapplicable laws and regulations.

RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

Your duty to inform us of changes.

It is important that the personal information we hold about you is accurate and current. Please keepus informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information.

Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a “data subject access request”).This enables you to receive a copy of the personal information we hold about you and to check thatwe are lawfully processing it.Request correction of the personal information that we hold about you. This enables you to have anyincomplete or inaccurate information we hold about you corrected.

Request the erasure of your personal information. This enables you to ask us to delete or removepersonal information where there is no good reason for us continuing to process it. You also have theright to ask us to delete or remove your personal information where you have exercised your right toobject to processing (see below).

Object to processing of your personal information where we are relying on legitimate interest (orthose of a third party) and there is something about your situation which makes you want to objectto processing on this ground. You also have the right to object where we are processing yourpersonal information for direct marketing purposes.

Request the restriction of processing of your personal information. This enables you to ask us tosuspend the processing of personal information about you, for example if you want us to establish itsaccuracy or the reason for processing it.

Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to theprocessing of your personal data, or request that we transfer a copy of your personal information toanother party, please contact the Data Compliance Manager in writing.

No fee usually required.

You will not have to pay a fee to access your personal information (or to exercise any of the otherrights). However, we may charge a reasonable fee if your request for access is clearly unfounded orexcessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensureyour right to access the information (or to exercise any of your other rights). This is anotherappropriate security measure to ensure that personal information is not disclosed to any person whohas no right to receive it.

RIGHT TO WITHDRAW CONSENT

In the limited circumstances where you may have provided your consent to the collection, processingand transfer of your personal information for specific purpose, you have the right to withdraw yourconsent, for that specific processing at any time. To withdraw your consent, please contact the DataCompliance Manager (George Leigh). Once we have received notification that you have withdrawnyour consent, we will no longer process your information for the purpose or purposes you originallyagreed to, unless we have another legitimate basis for doing so in law.

Introduction

Welcome to the Graft Ltd privacy policy.

Graft Ltd. respects your privacy and is committed to protecting your personal data. This privacy policywill inform you as to how we look after your personal data when you visit our website (regardless ofwhere you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in layered format so you can click through to the specific areas set outbelow. Please also use the Glossary to understand the meaning of some of the terms used in thisprivacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. DATA SECURITY
7. DATA RETENTION
8. YOUR LEGAL RIGHTS
9. GLOSSARY

1. Important Information and Who We Are

1.1 This privacy policy aims to give you information on how Graft Ltd. collects and processes yourpersonal data through your use of this website, including any data you may provide through thiswebsite when you register on our website.

It is important that you read this privacy policy together with any other privacy policy or fairprocessing policy we may provide on specific occasions when we are collecting or processingpersonal data, about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

This website is not intended for children, and we do not knowingly collect data relating to children.

1.2 ControllerGraft Ltd. is the controller and responsible for your personal data (referred to as “Graft Ltd.”, “we”,“us” or “our” in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legalrights, please contact us using the details set out below.

1.3 Contact detailsIf you have any questions about this privacy policy or our privacy practices, please contact us in thefollowing ways:Full name of legal entity: Graft Ltd

1.4 ComplaintsYou have the right to make a complaint at any time to the Information Commissioner’s Office (ICO),the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate thechance to deal with your concerns before you approach the ICO so please contact us using the detailsprovided above, in the first instance.

1.5 Changes to the privacy policy and your duty to inform us of changes.We keep our privacy policy under regular review. It is important that the personal data we holdabout you is accurate and current. Please keep us informed if your personal data changes during yourrelationship with us.

1.6 Third-party linksThis website may include links to third-party websites, plug-ins and applications. Clicking on thoselinks or enabling those connections may allow third parties to collect or share data about you. We donot control these third-party websites and are not responsible for their privacy statements. Whenyou leave our website, we encourage you to read the privacy policy of every website you visit.

2. The Data we Collect About You

2.1 Personal data, or personal information, means any information about an individual fromwhich that person can be identified. It does not include data where the identity has been removed(anonymous data).

2.2 We may collect, use, store and transfer different kinds of personal data about you which wehave grouped together as follows:

• Identity Data includes first name and last name.

• Contact Data includes email address and telephone numbers.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. This information will be autocollected by Google Analytics. Profile Data includes the details of any agency with which you areregistered. Usage Data includes information about how you use our website. Marketing andCommunications Data includes your preferences in receiving marketing from us and our third partiesand your communication preferences.

2.3 We also collect, use and share Aggregated Data such as statistical or demographic data forany purpose. Aggregated Data could be derived from your personal data but is not consideredpersonal data in law as this data will not directly or indirectly reveal your identity. For example, wemayaggregate your Usage Data to calculate the percentage of users accessing specific website feature.However, if we combine or connect Aggregated Data with your personal data so that it can directly orindirectly identify you, we treat the combined data as personal data which will be used in accordancewith this privacy policy.

2.4 We do not collect any Special Categories of Personal Data about you on our website (thisincludes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexualorientation, political opinions, trade union membership, information about your health, and geneticand biometric data). Nor do we collect any information about criminal convictions and offences. Ifyou are subsequently engaged by us, we may collect Special Categories of Personal Data about you,and you should review our privacy policy for employees and contractors which will be provided toyou. That policy details how we collect and deal with Special Categories of Personal Data.

2.5 Where we need to collect personal data by law, or under the terms of contract we have withyou, and you fail to provide that data when requested, we may not be able to perform the contractwe have or are trying to enter with you (for example, we may be unable to engage you as anemployee or contractor). In this Legitimate interest. The interest of our business in conducting and managing our business to enableus to give you the best service and the best and most secure experience. We make sure we considerand balance any potential impact on you (both positive and negative) and your rights before weprocess your personal data for our legitimate interests. We do not use your personal data foractivities where our interests are overridden by the impact on you (unless we have your consent orare otherwise required or permitted to by law). You can obtain further information about how weassess our legitimate interests against any potential impact on you in respect of specific activities bycontacting us.

Performance of contract. Processing your data where it is necessary for the performance of acontract to which you are a part or to take steps at your request before entering such a contract.

Comply with legal obligation. Processing your personal data where it is necessary for compliancewith legal obligations that we are subject to.

4.4 Marketing We strive to provide you with choices regarding certain personal data uses, particularly aroundmarketing and advertising.

4.5 Promotional offers from us We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what wethink you may want or need, or what may be of interest to you. This is how we decide which servicesand offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us orbeen provided with services from us and you have not opted out of receiving that marketing.
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4.6 Third-party marketingWe will get your express opt-in consent before we share your personal data with any third party formarketing purposes.

4.7 Opting out. You can ask us or third parties to stop sending you marketing messages at any time by contacting usat any time.

Where you opt out of receiving these marketing messages, this will not apply to personal dataprovided to us because of the service we have supplied to you or the contract we have entered withyou.

4.8 Cookies You can set your browser to refuse all or some browser cookies, or to alert you when websites set oraccess cookies. If you disable or refuse cookies, please note that some parts of this website maybecome inaccessible or not function properly. For more information about the cookies we use,please see.

4.9 Change of purposeWe will only use your personal data for the purposes for which we collected it, unless we reasonablyconsider that we need to use it for another reason and that reason is compatible with the originalpurpose. If you wish to get an explanation as to how the processing for the new purpose iscompatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explainthe legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, incompliance with the above rules, where this is required or permitted by law.

5. Disclosures of Your Personal Data

5.1 We may share your personal data with the parties set out below for the purposes set out inthe table promotional purposes.Apply to be engaged by us as a contractor or an agency.External Third Parties as set out in the Glossary. Specific Third Parties:

● Peterson James &Co Ltd

● Peterson James RewardsThird 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 change happens to ourbusiness, then the new owners may use your personal data in the same way as set out in this privacypolicy.

5.2 We require all third parties to respect the security of your personal data and to treat it inaccordance with the law. We do not allow our third-party service providers to use your personal datafor their own purposes and only permit them to process your personal data for specified purposesand in accordance with our instructions.

6. Data Security

6.1 We have put in place appropriate technical and organisational security controls to preventyour personal data from being accidentally lost, used or accessed in an unauthorised way, altered ordisclosed. In addition, we limit access to your personal data to those employees, agents, contractorsand other third parties who have business needs to know. They will only process your personal dataon our instructions and they are subject to the duty of confidentiality.

6.2 We have put in place procedures to deal with any suspected personal data breach and willnotify you and any applicable regulator of breach where we are legally required to do so.

7. Data Retention

7.1 We will only retain your personal data for as long as reasonably necessary to fulfil thepurposes 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 theevent of a complaint or if we reasonably believe there is prospect of litigation in respect to ourrelationship with you.

7.2 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 ordisclosure of your personal data, the purposes for which we process your personal data and whetherwe can achieve those purposes through other means, and the applicable legal, regulatory, tax,accounting or other requirements.

7.3 If you do become a contractor of Graft Ltd. or we enter into an agency agreement with youthen by law we must keep basic information about you (including Contact, Identity, financial andtransaction Data) for six years after you cease to be a contractor or in an agency relationship with usfor tax and related purposes.

7.4 In some circumstances you can ask us to delete your data: see your legal rights below forfurther information.

7.5 In some circumstances we will anonymise your personal data (so that it can no longer beassociated with you) for research or statistical purposes, in which case we may use this informationindefinitely without further notice to you.

8. Your Legal Rights

8.1 Under certain circumstances, you have rights under data protection laws in relation to yourpersonal data as described below.Request access to your personal data. Request correction of your personal data. Request erasure of your personal data.Object to processing of your personal data.

Request restriction of processing your personal data. Request transfer of your personal data.

Right to withdraw consent.If you wish to exercise any of the rights set out above, please contact us.

8.2 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 orexcessive. Alternatively, we could refuse to comply with your request in these circumstances.

8.3 What we may need from you.We may need to request specific information from you to help us confirm your identity and ensureyour right to access your personal data (or to exercise any of your other rights). This is a securitymeasure 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 upour response.

8.4 Time limit to respond.We try to respond to all legitimate requests within one month. Occasionally it could take us longerthan a month if your request is particularly complex or you have made several requests. In this case,we will notify you and keep you updated.

9. Your Legal Rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). Thisenables you to receive a copy of the personal data we hold about you and to check that we arelawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have anyincomplete or inaccurate data we hold about you corrected, though we may need to verify theaccuracy 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 datawhere there is no good reason for us continuing to process it. You also have the right to ask us todelete or remove your personal data where you have successfully exercised your right to object toprocessing (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 may notalways be able to comply with your request of erasure for specific legal reasons which will be notifiedto you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on legitimate interest (or those of athird party) and there is something about your situation which makes you want to object toprocessing on this ground as you feel it impacts on your fundamental rights and freedoms. You alsohave the right to object where we are processing your personal data for direct marketing purposes.In some cases, we may demonstrate that we have compelling legitimate 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 theprocessing 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 toestablish, exercise or defend legal claims.

•You have objected to our use of your data, but we need to verify whether we have overridinglegitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or athird party you have chosen, your personal data in a structured, commonly used, machine-readableformat. Note that this right only applies to automated information which you initially providedconsent 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

THIRD PARTIES

External Third Parties

Service providers acting as processors based in the UK who provide IT and system administrationservices. Professional advisers acting as processors or joint controllers including lawyers, bankers,auditors and insurers based in the United Kingdom who provide consultancy, banking, legal,insurance and accounting services.

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllersbased in the United Kingdom.

CONTACT INFORMATION

Should you wish to discuss any element of Graft Ltd. company structure, operational processes orcommercial proposition, please contact: