BANQUE TRANSATLANTIQUE LONDON BRANCH PRIVACY POLICY to, through and from our site (including date and time), MARKETING BANQUE TRANSATLANTIQUE LONDON BRANCH products you viewed or searched for, page response times, download errors, length of visits to certain pages, From time to time, we would like to send you information PRIVACY POLICY page interaction information (such as scrolling, clicks, by email and/or other means as may be agreed to by and mouse-overs),and methods used to browse away you about any of our similar services, products and – when you complete certain forms, including forms to ABOUT US from the page and any phone number used to call our opportunities which may be of interest to you. become a client of the Bank, in person, in writing or by customer service number. Banque Transatlantique S.A. London Branch corresponding with us by phone, email or otherwise; We will ask whether you would like us to send you these (“we”/“our”/“us”/”the Branch”) takes your privacy very emails and/or notifications as part of our onboarding seriously and is committed to protecting and respecting – when you register to use our services, including Our website also places cookies on your terminal process. your privacy. applying to become a client of the Bank or any other product or service; equipment (please see our Cookie Policy for more If you change your mind and do not want us to use your information about this). Banque Transatlantique S.A. is incorporated in France as – when you provide us with instructions to act on your personal data in this way, please contact our Compliance a public limited company by shares (Société Anonyme) behalf; Team by sending an email to btlbcompliance@ with its headquarters at 26, avenue Franklin D. Roosevelt, banquetransatlantique.com 75008 Paris, France and registered with the Paris registry – if you complete a survey, provide feedback or report a Information provided by third parties. of companies (Greffe Du Tribunal De Commerce De Paris) problem; We will not provide your personal data to any other third – We may receive information about you if you use any of party businesses for marketing purposes. with registration number 302 695 937. – if you contact or correspond with us (for example, by the other websites we operate or the other services we post, phone, e-mail, in person or otherwise) for any provide. We work closely with third parties (including, for The UK establishment address of Banque Transatlantique other reason. S.A. London Branch is at Finsbury Circus House, 15 example, other members of the Banque Transatlantique Finsbury Circus, London, EC2M 7EB, United Kingdom. The information you give us may include your: Group, our sub-contractors in technical, payment and DISCLOSURE OF YOUR PERSONAL DATA – delivery services, credit reference agencies, and fraud name; We do not sell, rent or trade your personal data. Banque Transatlantique S.A. London Branch (BTLB) prevention agencies) and may receive information – date of birth; is registered in the United Kingdom as a branch of an about you from them. We may give access to your personal data, and allow overseas company under number BR009959. BTLB is – age; . its processing, by other members of the Banque authorised and regulated by Banque de France. Deemed – address; Transatlantique Group in order to support us in the authorised by the Prudential Regulation Authority. Subject – email address; USES MADE OF THE INFORMATION performance of the activities listed above under “Uses to regulation by the Financial Conduct Authority and limited made of the information”. regulation by the Prudential Regulation Authority. Details – phone number and mobile telephone number; We will use personal data held about you in the following of the Temporary Permissions Regime, which allows EEA- – gender; ways: You acknowledge that we may share your personal data, and allow its processing, within a strictly defined scope based firms to operate in the UK for a limited period while – nationality; – to carry out our obligations arising from any agreements seeking full authorisation, are available on the Financial entered into between you and us, including to provide and purpose to the following categories of selected third – employment status; Conduct Authority’s website. you with the information, products and services that you parties: – financial and credit history; request from us, and to notify you about changes to our – our third party service providers, agents and This Privacy Policy together with our Website Terms of – children’s names and date of birth; and products or services; subcontractors for the performance of any contract we Use, Cookie Policy and any other documents referred to in – enter into with them. This includes among others: our it, sets out the basis on which any personal data we collect – financial knowledge and experience information. to provide you with the rights, benefits, and entitlements, IT service providers (currently EI and CM11-CIC Market about you will be processed by us. and other conditions as applicable under the contractual relationship between you and us; Solutions; We hope you will provide us with this information. However, Please read the following carefully to understand our – to help us to verify your identity; – analytics and search engine providers that assist us in views and practices regarding your personal data and how if you do not want to disclose your personal data to us, – the improvement and optimisation of our services; and we will treat it. please to process and verify your financial transactions, – other financial institutions, credit reference agencies and be aware that without it, in some cases, we will not be including the detection and prevention of fraud; Banque Transatlantique S.A. London Branch is the Data fraud prevention agencies for the purposes of making able to provide you with the product or service you have – to perform credit checks and to obtain or provide credit Controller and is registered with the UK Information credit assessments and detecting and preventing fraud, requested. references; Commissioner’s Office with registration number Z3655559. money laundering and other crimes. – to collect any money you owe us; Its registered office is at Finsbury House, 15 Finsbury We may also disclose your personal data to third parties: INFORMATION WE COLLECT ABOUT YOU – to comply with our obligations under regulations Avenue, London, EC2M 7EB, United Kingdom. applicable to our cooperation with you, such as tax – in the event that we sell, buy or in other way transfer We will collect the following information about you: By providing your personal data either electronically or in laws and including in relation to money laundering and any business or assets, in which case we may disclose – paper form, you are accepting the practices described in details of all financial transactions, whether requested terrorist financing; your personal data to the prospective seller, buyer or in person, over the phone, via email, or through the this Privacy Policy. – to deal with any enquiries, correspondence, concerns acquirer of such business or assets; post; or complaints you have raised; – if our company or substantially all of its assets are – technical information, for example, the type of device – for our internal operations, including data analysis, acquired by a third party, in which case personal data (and its unique device identifier) you use to access testing, research, statistical purposes and held by us about our customers will be one of the WHO DOES THIS POLICY APPLY TO? our platforms, the Internet Protocol (IP) address troubleshooting; transferred assets; This Privacy Policy applies to all customers and used to connect your device to the Internet, your login – – to ensure that content from our site is presented in the if we are under a duty to disclose or share your personal prospective customers of Banque Transatlantique S.A. information, browser type and version, time zone most effective manner for you and for your computer data in order to comply with any legal obligation or in London Branch. setting, browser plug-in types and versions, operating and for your device; order to enforce or apply our policies and/or terms of system, mobile network information and platform; and use and/or other applicable agreements or to protect our – as part of our efforts to keep our services secure; and DATA WE COLLECT FROM AND ABOUT YOU – information about your visit to our website, including rights, property, or safety of our customers, or others. the full Uniform Resource Locators (URL) clickstream – to respond to requests and legal demands from This includes exchanging information with other We will collect the information you give us: regulators or other authorities. companies and organisations for the purposes of fraud protection and credit risk reduction.

| PAGE 9 | BANQUE TRANSATLANTIQUE LONDON BRANCH | PRIVACY POLICY BANQUE TRANSATLANTIQUE LONDON BRANCH | PRIVACY POLICY | PAGE 10 | WHERE WE STORE YOUR PERSONAL DATA the processing is unlawful or we no longer need your Publication date: [23 June 2020] personal information for the purposes of the processing. We will only process and store your personal data in the EEA. – Change of preferences. You can change your data MORE ABOUT THE PERSONAL DATA WE processing preferences at any time using the details COLLECT AND WHY provided below or clicking the relevant link in any SECURITY communication you receive. All information you provide to us is stored on secure – omplaints. Questions, comments and requests servers. regarding this Privacy Policy are welcomed and should Purpose Information Legal Basis Source be addressed to BTLB Compliance btlbcompliance@ We will use technical and organisational measures to To carry out our – name; – we process your information You provide this safeguard your personal data. banquetransatlantique.com. obligations arising – date of birth; with your consent; information to us when from any agreements you open an account Where we have given you (or where you have chosen) – age; – we process your information a password or other identifying information which If for any reason you are not happy with the way that we entered into between when we need to do this to fulfil a with us as part of our – address; enables you to access one or more of our services, you have handled your personal data, please contact BTLB you and us, including contract with you client on-boarding Compliance [email protected]. to provide you with the – email address; process are responsible for keeping that password confidential. –We process your information information, products We ask you not to share your password with anyone – phone number and mobile where we are required to comply and services that you else. If you lose control of your password, you may lose If you are still not happy, you have the right to make a telephone number; with laws in relation to money request from us, and substantial control over your personal data. Therefore, if complaint to the UK Information Commissioner’s Office. – gender; laundering and terrorist financing. your password has been compromised for any reason, you to notify you about – Data portability. In some circumstances, you have the –We process your information should immediately notify us using the details provided changes to our products – nationality; right to request a copy of the personal data we hold when it is in our legitimate under the section “Your rights”. or services. – employment status; about you, in a structured, electronic format, and to interests to do this and when – financial and credit transmit such data to another organisation. these interests are not overridden RETAINING PERSONAL DATA history; – Retention. We do retain personal data from closed by your data protection rights. For We will retain the personal data we receive or collect accounts to comply with law, prevent fraud, collect any – children’s names and example, we have a legitimate about you for the period reasonably required for us to use fees owed, resolve disputes, troubleshoot problems, date of birth; and interest in notifying you about it in accordance with this Policy or in accordance with our assist with any investigations, and take other actions – financial knowledge and changes to products or services legal rights and obligations. We may need to retain some otherwise permitted by law. experience information. that may be relevant to you. of your personal data for 6 years after you stop using our Please note that if you ask us to stop processing your products and services, for legal reasons, for example, in personal data in a certain way or erase your personal To provide you with the – name; We process your information You provide this case you make a complaint. Non-personal information can data, and this type of processing or data is needed for us rights, benefits, and when we need to do this to fulfil a information to us when be stored indefinitely. – date of birth; to provide you with certain services, you may not be able entitlements, and other contract with you you open an account – age; Unless we inform you otherwise (or you request that we to use those services as you did before. This does not conditions as applicable with us as part of our erase your personal data), we will retain your personal include your right to object to direct marketing, which can under the contractual – address; client on-boarding data on record for as long as you continue to use our be exercised at any time without restriction. relationship between – email address; process products and services and thereafter only for as long as If you would like to exercise any of the rights mentioned you and us. – phone number and mobile we are legally required to do so including in connection above, please contact us by emailing BTLB Compliance telephone number; with legal proceedings. [email protected].. – gender; . You can always change your mind about our processing of – nationality; your personal data. If you change your mind you can contact – employment status; YOUR RIGHTS us by emailing btlbcompliance@banquetransatlantique. – financial and credit history; You have the following rights with regard to your personal com or on our main number +44(0)20 3618 9750, or in – children’s names and date data: respect of marketing messages, you can unsubscribe by using the unsubscribe link at the bottom of those marketing of birth; and – Marketing. Further to the section headed “Marketing”, messages. – financial knowledge and you have the right to ask us not to process your personal experience information data for marketing purposes. CHANGES TO OUR PRIVACY POLICY To help us to verify your – name; We process your information You provide this – Access. You have the right to obtain confirmation as to Any changes we may make to our Privacy Policy in the identity, to process and – date of birth; where we are required to comply information to us when whether or not your personal data is being processed, future will be posted on our website. They will be effective verify your financial with laws in relation to money you open an account and,if it is, request access to that personal data. We will – age; as of the publication date. transactions, including laundering and terrorist financing with us as part of our need you to prove your identity before we release any the detection and – address; .We process your information client on-boarding personal data to you. – email address; when it is in our legitimate process. prevention of fraud, to – Rectification or erasure. You have the right to request interests to do this and when perform credit checks – phone number and mobile that we rectify or delete any personal data that we hold these interests are not overridden and to obtain or provide telephone number; about you (unless we have the legal right to retain it). by your data protection rights. credit references and to – gender; – Restriction. You also have the right to restrict us from collect any money you – nationality; processing your personal data if the data is inaccurate, owe us. – employment status; – financial and credit history.

| PAGE 11 | BANQUE TRANSATLANTIQUE LONDON BRANCH | PRIVACY POLICY BANQUE TRANSATLANTIQUE LONDON BRANCH | PRIVACY POLICY | PAGE 12 | MORE ABOUT THE PERSONAL DATA WE MORE INFORMATION ABOUT YOUR CHOICES IN RESPECT OF OUR USE OF YOUR COLLECT AND WHY PERSONAL DATA You have the right to access, rectify, block, complete and delete your personal data, and to restrict its use. You also have the right to request further information about the processing of your personal data; and Purpose Information Legal Basis Source In certain circumstances, you also have the right to object to the processing of your personal data by us.

To comply with our – name; We process your information You provide this obligations under – date of birth; where we are required to information to us when You can exercise the above rights by contacting us using the details provided above at any time. All requests will be dealt regulations applicable comply with laws in relation to you open an account – age; with at the earliest opportunity and any delay will be kept to a minimum. to our cooperation with money laundering and terrorist with us as part of our you, such as tax laws – address; financing .We process your client on-boarding and including in relation – email address; information when it is in our process. There are exceptions to these rights; for example, access may be refused if it would reveal personal data about another to money laundering – phone number and mobile legitimate interests to do this person or if we are prevented from disclosing such information by law. and terrorist financing. telephone number; and when these interests are not overridden by your data You also have the right to make a complaint to the Information Commissioner’s Office or to seek a remedy through the – gender; protection rights. courts if you believe that your rights have been breached. – nationality; When we ask you to supply us with information, we will make it clear whether the information we are asking for must be – employment status; supplied so that we can provide the products and services to you, or whether the supply of any information we ask for – financial and credit history. is optional. To ensure that content – we may collect information – We process your information You provide this from our site is and data obtained from when it is in our legitimate information to us when presented in the most use of our website and interests to do this and when you visit our website or MORE INFORMATION ABOUT OUR RETENTION OF YOUR PERSONAL DATA effective manner for you other platforms including these interests are not overridden use our other platforms. and for your device. communications, by your data protection rights. We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for transactions and location For example, to improve your the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention data and from placing user experience in using our site period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm cookies on our website and mobile banking app”). from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and (please see our Cookie whether we can achieve those purposes through other means, and the applicable legal requirements. Policy for more information We will, in general, retain personal data to comply with our legal and regulatory obligations. about this) Where Your Personal Data is no longer required by us, we will either securely delete or anonymise the personal data in question. For our internal – name; We process your information You provide this operations, including – address; when it is in our legitimate information to us when data analysis, testing, interests to do this and you visit our website or – email address; research, statistical when these interests are use our other platforms. MORE INFORMATION ABOUT WITH WHOM WE SHARE YOUR PERSONAL DATA – phone number and mobile purposes and not overridden by your data Like many businesses, we share information with members of our Group and contract with other companies to perform troubleshooting. telephone number; protection rights. For example, – gender; we have a legitimate interest in certain business-related functions, such as credit collection agencies, customer support services providers and other service providers. When we do, we may share with them information that they require to perform their specific functions. – nationality; administering our website. – financial and transactions history. Suppliers to us that have access to your personal data are required to keep the data confidential, maintain appropriate To respond to requests – name; We process your information You provide this security and are not permitted to use the data for any purpose other than to carry out the services they are performing and legal demands – date of birth; where we are required to information to us when for us. from regulators or other comply with laws in relation to you open an account – age; authorities. money laundering and terrorist with us as part of our – address; financing .We process your client on-boarding Our Group members and their locations are as follows: – email address; information when it is in our process and when – Banque Transatlantique SA (France) – phone number and mobile legitimate interests to do this making transactions telephone number; and when these interests are using your account – CM11-CIC Market Solutions (France) not overridden by your data – gender; protection rights. – Euro-information (France) – nationality; – employment status; – financial and credit history; – transaction history; – asset portfolio.

| PAGE 13 | BANQUE TRANSATLANTIQUE LONDON BRANCH | PRIVACY POLICY BANQUE TRANSATLANTIQUE LONDON BRANCH | PRIVACY POLICY | PAGE 14 | PARIS

BRUSSELS

GENEVA

HONG KONG

LONDON

LUXEMBOURG

MONTREAL

NEW YORK

BOSTON

SAN FRANCISCO

SINGAPORE

Banque Transatlantique SA, Finsbury Circus House, 15 Finsbury Circus, London EC2M 7EB, UK. T: +44 203 618 9750 E: btlondres@ banquetransatlantique.com Banque Transatlantique SA is authorised by the Banque de France (Autorité de Contrôle Prudentiel et de Résolution). Banque Transatlantique SA has a Board of Directors, a Supervisory Board and an issued capital of €29,371,680 (RCS Paris 302 695 937). Registration in the UK: Company No. FC018936, Branch No. BR009959 https://www.banquetransatlantique.co.uk

Banque Transatlantique London Branch @BT_London 020 3618 9750 V1 – 09/18

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