BANQUE TRANSATLANTIQUE BRANCH PRIVACY POLICY BANQUE TRANSATLANTIQUE LONDON BRANCH PRIVACY POLICY

ABOUT US –– when you provide us with instructions to act on your behalf; Banque Transatlantique S.A. London Branch (“we”/“our”/“us”) –– if you complete a survey, provide feedback or report a takes your privacy very seriously and is committed to protecting problem; and respecting your privacy. –– if you contact or correspond with us (for example, by post, phone, e-mail, in person or otherwise) for any other reason. Banque Transatlantique S.A. London Branch is incorporated in as a public limited company by shares (Societe The information you give us may include your: Anonyme) with its headquarters at 26, avenue Franklin D. –– name; Roosevelt, 75008 , France and registered with the Paris –– date of birth; registry of companies (Greffe Du Tribunal De Commerce De Paris) with registration number 302 695 937. –– age; –– address; The UK establishment address of Banque Transatlantique S.A. London Branch is at Finsbury Circus House, 15 Finsbury Circus, –– email address; London, EC2M 7EB, United Kingdom. –– phone number and mobile telephone number; Banque Transatlantique S.A. London Branch is authorised by –– gender; Banque de France and subject to limited regulation by the –– nationality; Financial Conduct Authority and Prudential Regulation Authority. –– employment status; Details about the extent of our regulation by the Financial –– financial and credit history; Conduct Authority and the Prudential Regulation Authority are available from us on request. –– children’s names and date of birth; and –– financial knowledge and experience information. This Privacy Policy together with our Website Terms of Use, Cookie Policy and any other documents referred to in it, sets We hope you will provide us with this information. However, out the basis on which any personal data we collect about you if you do not want to disclose your personal data to us, please will be processed by us. be aware that without it, in some cases, we will not be able to Please read the following carefully to understand our views provide you with the product or service you have requested. and practices regarding your personal data and how we will treat it. INFORMATION WE COLLECT ABOUT YOU Banque Transatlantique S.A. London Branch is the Data We will collect the following information about you: Controller and is registered with the UK Information –– details of all financial transactions, whether requested in Commissioner’s Office with registration number Z3655559. person, over the phone, via email, through the post or via Its registered office is at Finsbury House, 15 Finsbury Avenue, our BTLB Mobile Banking App; London, EC2M 7EB, United Kingdom. The Data Protection –– details of your usage of our BTLB Mobile Banking Officer is Ana Oliveira, who can be contacted at App (including the date, time, location and duration [email protected]. of the usage); By providing your personal data as part of our account opening –– technical information, for example, the type of device (and process either electronically or in paper form, you are accepting its unique device identifier) you use to access the BTLB the practices described in this Privacy Policy. Mobile Banking App, the Internet Protocol (IP) address used to connect your device to the Internet, your login WHO DOES THIS POLICY APPLY TO? information, browser type and version, time zone setting, browser plug-in types and versions, operating system, This Privacy Policy applies to all customers and prospective mobile network information and platform; and customers of Banque Transatlantique S.A. London Branch. –– information about your visit to our website, including the full Uniform Resource Locators (URL) clickstream to, through DATA WE COLLECT FROM AND ABOUT YOU and from our site (including date and time), products you We will collect the information you give us: viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction –– when you complete certain forms, including forms to open information (such as scrolling, clicks, and mouse-overs), an account with us, in person, in writing or by corresponding and methods used to browse away from the page and any with us by phone, email or otherwise; phone number used to call our customer service number. –– when you register to use our services, including applying for an account or any other product or service, or registering Our website also places cookies on your terminal equipment to use our BTLB Mobile Banking App; (please see our Cookie Policy for more information about this).

| PAGE 2 | BANQUE TRANSATLANTIQUE LONDON BRANCH | PRIVACY POLICY Information provided by third parties. MARKETING –– We may receive information about you if you use any of From time to time, we would like to send you information by the other websites we operate or the other services we email and/or notifications on our BTLB Mobile Banking App provide. We work closely with third parties (including, for about any of our similar services, products and opportunities example, other members of the Banque Transatlantique which may be of interest to you. Group, our sub-contractors in technical, payment and delivery services, credit reference agencies, and fraud We will ask whether you would like us to send you these emails prevention agencies) and may receive information and/or notifications when you open an account with us and/or about you from them. when you first complete your registration on the BTLB Mobile Banking App. Click here to learn more about the information we collect. If you change your mind and do not want us to use your USES MADE OF THE INFORMATION personal data in this way, please contact our Data Protection Officer, Ana Oliveira, by sending an email to We will use personal data held about you in the following ways: [email protected]. –– to carry out our obligations arising from any agreements We will not provide your personal data to any other third party entered into between you and us, including under our businesses for marketing purposes. General Banking Terms and Conditions (Personal Accounts) and under our Mobile Banking App Terms and Conditions DISCLOSURE OF YOUR PERSONAL DATA and to provide you with the information, products and services that you request from us, including using our We do not sell, rent or trade your personal data. BTLB Mobile Banking App (where you have registered for this service) and to notify you about changes to our We may give access to your personal data, and allow its products or services; processing, by other members of the Banque Transatlantique Group in order to support us in the performance of the –– to provide you with the rights, benefits, and entitlements, activities listed above under “Uses made of the information”. and other conditions as applicable under the contractual relationship between you and us; You acknowledge that we may share your personal data, and –– to help us to verify your identity; allow its processing, within a strictly defined scope and purpose to the following categories of selected third parties: –– to process and verify your financial transactions, including the detection and prevention of fraud; –– our third party service providers, agents and subcontractors for the performance of any contract we enter into with –– to perform credit checks and to obtain or provide them. This includes among others: our IT service provider credit references; (currently EII), our security solution provider (currently –– to collect any money you owe us; LuxTrust SA), our debit card service provider (currently FIS), –– to comply with our obligations under regulations applicable our direct debit service provider (currently Bottom Line) to our cooperation with you, such as tax laws and including and CM11-CIC Market Solutions; in relation to money laundering and terrorist financing; –– analytics and search engine providers that assist us in the –– to deal with any enquiries, correspondence, concerns or improvement and optimisation of our services; and complaints you have raised; –– other financial institutions, credit reference agencies and –– for our internal operations, including data analysis, testing, fraud prevention agencies for the purposes of making credit research, statistical purposes and troubleshooting; assessments and detecting and preventing fraud, money –– to ensure that content from our site and on our mobile laundering and other crimes. banking app is presented in the most effective manner for We may also disclose your personal data to third parties: you and for your computer and for your device; –– in the event that we sell, buy or in other way transfer any –– as part of our efforts to keep our services (including our business or assets, in which case we may disclose your mobile banking app) secure; and personal data to the prospective seller, buyer or acquirer of –– to respond to requests and legal demands from regulators such business or assets; or other authorities. –– if our company or substantially all of its assets are acquired Click here to learn more about how we use the information by a third party, in which case personal data held by it about we collect. its customers will be one of the transferred assets; –– if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or in order to enforce or apply our policies and/or terms of use and/or other applicable agreements or to protect our rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. Click here to learn more about how we share the information which we collect.

BANQUE TRANSATLANTIQUE LONDON BRANCH | PRIVACY POLICY | PAGE 3 | WHERE WE STORE YOUR PERSONAL DATA –– Complaints. Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to We will only process and store your personal data in the EEA. Ana Oliveira [email protected] and cc BTLB Compliance [email protected]. SECURITY If for any reason you are not happy with the way that All information you provide to us is stored on secure severs. we have handled your personal data, please contact We will use technical and organisational measures to safeguard Ana Oliveira [email protected] and cc your personal data. BTLB Compliance [email protected]. If you are still not happy, you have the right to make a Where we have given you (or where you have chosen) a complaint to the UK Information Commissioner’s Office. password or other identifying information which enables you to –– Data portability. In some circumstances, you have the right access one or more of our services, including our BTLB Mobile to request a copy of the personal data we hold about you, Banking App, you are responsible for keeping that password in a structured, electronic format, and to transmit such data confidential. We ask you not to share your password with to another organisation. anyone else. If you lose control of your password, you may lose substantial control over your personal data. Therefore, if your –– Retention. We do retain personal data from closed password has been compromised for any reason, you should accounts to comply with law, prevent fraud, collect any immediately notify us using the details provided under the fees owed, resolve disputes, troubleshoot problems, assist section “Your rights”. with any investigations, and take other actions otherwise permitted by law. RETAINING PERSONAL DATA Please note that if you ask us to stop processing your personal data in a certain way or erase your personal data, and this type We will retain the personal data we receive or collect about of processing or data is needed for us to provide you with you for the period reasonably required for us to use it in certain services, you may not be able to use those services as accordance with this Policy or in accordance with our legal you did before. This does not include your right to object to rights and obligations. We may need to retain some of your direct marketing, which can be exercised at any time without personal data for 6 years after you stop using our products restriction. and services, for legal reasons, for example, in case you make a complaint. Non-personal information can be stored indefinitely. If you would like to exercise any of the rights mentioned above, please contact us by emailing Ana Oliveira Unless we inform you otherwise (or you request that we erase [email protected] and cc BTLB your personal data), we will retain your personal data on record Compliance [email protected]. for as long as you continue to use our products and services and thereafter only for as long as we are legally required to do Click here to learn more about the additional rights you may so including in connection with legal proceedings. have in relation to your personal data.

YOUR RIGHTS You can always change your mind about our processing of your personal data. If you change your mind you can contact us by You have the following rights with regard to your personal data: emailing Ana Oliveira [email protected] and cc BTLB Compliance [email protected] Marketing. ––  Further to the section headed “Marketing”, you or on our main number +44(0)20 3618 9750, or in respect have the right to ask us not to process your personal data of marketing messages you can unsubscribe by using the for marketing purposes. unsubscribe link at the bottom of those marketing messages. –– Access. You have the right to obtain confirmation as to whether or not your personal data is being processed, and, Click here to learn more about how long we retain your if it is, request access to that personal data. We will need personal data for. you to prove your identity before we release any personal data to you. CHANGES TO OUR PRIVACY POLICY –– Rectification or erasure. You have the right to request that Any changes we may make to our Privacy Policy in the future we rectify or delete any personal data that we hold about will be posted on our website. They will be effective as of the you (unless we have the legal right to retain it). publication date. Restriction. ––  You also have the right to restrict us from Publication date: [31 January 2018] processing your personal data if the data is inaccurate, the processing is unlawful or we no longer need your personal information for the purposes of the processing. –– Change of preferences. You can change your data processing preferences at any time using the details provided below or clicking the relevant link in any communication you receive.

| PAGE 4 | BANQUE TRANSATLANTIQUE LONDON BRANCH | PRIVACY POLICY MORE ABOUT THE PERSONAL DATA WE COLLECT 2. To provide you with the rights, benefits, and entitlements, AND WHY and other conditions as applicable under the contractual relationship between you and us. 1. To carry out our obligations arising from any agreements entered into between you and us, including under our a. what information do we collect? General Banking Terms and Conditions (Personal Accounts) –– name; and under our Mobile Banking App Terms and Conditions –– date of birth; and to provide you with the information, products and services that you request from us, including using our –– age; BTLB Mobile Banking App (where you have registered –– address; for this service) and to notify you about changes to our –– email address; products or services. –– phone number and mobile telephone number; a. what information do we collect? –– gender; –– name; –– nationality; –– date of birth; –– employment status; –– age; –– financial and credit history; –– address; –– children’s names and date of birth; and –– email address; –– financial knowledge and experience information –– phone number and mobile telephone number; b. what is the legal basis for collecting this information? –– gender; We process your information when we need to do –– nationality; this to fulfil a contract with you (for example, Mobile –– employment status; Banking App Terms and Conditions). –– financial and credit history; c. what is the source of this information? –– children’s names and date of birth; and You provide this information to us when you open a bank –– financial knowledge and experience information. account with us as part of our client on-boarding process  b. what is the legal basis for collecting this information? or when you register to use the BTLB Mobile Banking App. –– we process your information with your consent; 3. To help us to verify your identity, to process and verify –– we process your information when we need to your financial transactions, including the detection and do this to fulfil a contract with you (for example, prevention of fraud, to perform credit checks and to the Mobile Banking App Terms and Conditions); obtain or provide credit references and to collect any money you owe us. –– we process your information where we are required to do this by law (for example, where a. what information do we collect? it is necessary to retain it in connection with –– name; potential litigation); or –– date of birth; –– we process your information when it is in –– age; our legitimate interests to do this and when these interests are not overridden by your –– address; data protection rights. For example, we have a –– email address; legitimate interest in delivering the requested –– phone number and mobile telephone number; products or services and of changes to the –– gender; products or services. –– nationality; c. what is the source of this information? –– employment status; You provide this information to us when you –– financial and credit history. open a bank account with us as part of our client on-boarding process or when you register to use b. what is the legal basis for collecting this information? the BTLB Mobile Banking App. We process your information where we are required to do this by law (for example, where it is necessary to retain it in connection with potential litigation); or We process your information when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, we have a legitimate interest in delivering the requested products or services.

BANQUE TRANSATLANTIQUE LONDON BRANCH | PRIVACY POLICY | PAGE 5 | c. what is the source of this information? 7. For our internal operations, including data analysis, testing, You provide this information to us when you research, statistical purposes and troubleshooting. open a bank account with us as part of our client a. what information do we collect? on-boarding process. –– name; 4. To comply with our obligations under regulations –– address; applicable to our cooperation with you, such as tax –– email address; laws and including in relation to money laundering and terrorist financing. –– phone number and mobile telephone number; a. what information do we collect? –– gender; –– nationality; –– name; –– financial and transactions history. –– date of birth; –– age; b. what is the legal basis for collecting this information? –– address; We process your information when it is in our legitimate interests to do this and when these –– email address; interests are not overridden by your data protection –– phone number and mobile telephone number; rights. For example, we have a legitimate interest in –– gender; administering our website. –– nationality; c. what is the source of this information? –– employment status; You provide this information to us when you –– financial and credit history. open a bank account with us as part of our client b. what is the legal basis for collecting this information? on-boarding process and when making transactions using your account and when you browse We process your information where we are required our website. to do this by law (for example, where it is necessary to retain it in connection with potential litigation). 8. As part of our efforts to keep our services (including our BTLB Mobile Banking App) secure. c. what is the source of this information? a. what information do we collect? You provide this information to us when you open a bank account with us as part of our –– name; client on-boarding process. –– email address; 5. To ensure that content from our site and on our mobile –– phone number and mobile telephone number; banking app is presented in the most effective manner –– connection history; for you and for your computer and for your device. –– device features; a. what information do we collect? –– LuxTrust Certificate details. –– we may collect information and data obtained b. what is the legal basis for collecting this information? from use of our mobile banking app, including We process your information when it is in our communications, transactions and locations legitimate interests to do this and when these data and from placing cookies on our website interests are not overridden by your data protection (please see our Cookie Policy for more rights. For example, we have a legitimate interest in information about this) ensuring that all personal data collected or otherwise b. what is the legal basis for collecting this information? processed through our BTLB Mobile Banking App are –– we process your information when it is in our safe and secure. legitimate interests to do this and when these c. what is the source of this information? interests are not overridden by your data protection rights. You provide this information to us when you order a c. what is the source of this information? LuxTrust Certificate as part of registering to use our BTLB Mobile Banking App. You provide this information to us when you browse our website or when you use our BTLB Mobile Banking App.

| PAGE 6 | BANQUE TRANSATLANTIQUE LONDON BRANCH | PRIVACY POLICY 9. To respond to requests and legal demands from MORE INFORMATION ABOUT OUR RETENTION regulators or other authorities. OF YOUR PERSONAL DATA a. what information do we collect? Click here for more information about our retention of –– name; personal data. –– date of birth; MORE INFORMATION ABOUT WITH WHOM WE –– age; SHARE YOUR PERSONAL DATA –– address; –– email address; Like many businesses, we share information with members of our Group and contract with other companies to perform –– phone number and mobile telephone number; certain business-related functions, such as credit collection –– gender; agencies, customer support services providers and other service –– nationality; providers. When we do, we may share with them information –– employment status; that they require to perform their specific functions. Suppliers to us that have access to your personal data are required to keep –– financial and credit history; the data confidential, maintain appropriate security and are not –– transaction history; permitted to use the data for any purpose other than to carry –– asset portfolio. out the services they are performing for us. b. what is the legal basis for collecting this information? Our Group members and their locations are as follows: We process your information where we are required –– Euro Information International (Luxembourg) to do this by law (for example, where it is necessary –– Banque Transatlantique SA (France) to retain it in connection with potential litigation). –– CM11-CIC Market Solutions (France) c. what is the source of this information? –– Banque du Luxembourg (Luxembourg) You provide this information to us when you –– Euro-information (France) open a bank account with us as part of our client on-boarding process and when making transactions Example of our suppliers and their locations are as follows: using your account. –– LuxTrust (Luxembourg) –– FIS (UK) MORE INFORMATION ABOUT YOUR CHOICES IN –– Bottom Line (UK) RESPECT OF OUR USE OF YOUR PERSONAL DATA –– RBS (UK) 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 In certain circumstances, you also have the right to object to the processing of your personal data by us. You can exercise the above rights by contacting us using the details provided above at any time. All requests will be dealt with at the earliest opportunity and any delay will be kept to a minimum. There are exceptions to these rights; for example, access may be refused if it would reveal personal data about another person or if we are prevented from disclosing such information by law. You also have the right to make a complaint to the Information Commissioner’s Office or to seek a remedy through the courts if you believe that your rights have been breached. When we ask you to supply us with information we will make it clear whether the information we are asking for must be supplied so that we can provide the products and services to you, or whether the supply of any information we ask for is optional.

BANQUE TRANSATLANTIQUE LONDON BRANCH | PRIVACY POLICY | PAGE 7 | PARIS

BARCELONA

BRUSSELS

GENEVA

HONG KONG

LONDON

LUXEMBOURG

MADRID

MONTREAL

NEW YORK

SAN FRANCISCO

SINGAPORE

Banque Transatlantique SA, Finsbury Circus House, 15 Finsbury Circus, London EC2M 7EB, UK. T: +44 203 618 9750 E: [email protected] 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 www.banquetransatlantique.co.uk

Banque Transatlantique London Branch @BT_London 020 3618 9750 V1 – 01/18