Privacy Policy

February 2021

www.simpsongrierson.com

LAST UPDATED: 26 FEBRUARY 2021

Introduction services, providing us with personal information, visiting our website, or Your privacy is important to us, and we are using our online portal for customer committed to ensuring that your personal due diligence; information is protected.  "products and services" means all This Privacy Policy explains how we collect, products and services we provide and use and disclose the personal information anything else we do for you, including that we collect from you or which we have providing you with access to our obtained about you from a third party. It website or online portal for customer sets out various rights that you have in due diligence; and relation to that personal information.  "website" means our website accessible Please take a moment to read and at www.simpsongrierson.com, or understand it. associated websites or pages, including

any data room or online portal that we This Privacy Policy explains: may make available to clients or  how we collect personal information; potential clients.  the kind of personal information we We may modify or amend this Privacy collect; Policy at any time and for any reason. You can view our most current Privacy Policy on  how we use, and may share, your our website. personal information;

 how we use cookies and log files; How we collect personal information  responsibility for personal information We collect personal information in the collected through linked third party following ways: websites;  directly from you or from third parties  how you can access/amend your acting on your authority or who you personal information; authorise us to make contact with about you:  how long we hold personal information; o when you contact us seeking  who you can contact for further information about us, our products information; and or services or anything on our  additional terms that apply to some website (including when you residents of the European Economic register on our website to receive Area. our news and updates service or to access information made available

only to registered users); In this Privacy Policy: o in the course of conducting  "we" means Simpson Grierson or any customer due diligence; related company providing you with our products or services; o in the course of providing our products and services to you; or  "you" means you, the person purchasing or using our products or

o when you apply to work at Simpson  to carry out your instructions, deliver Grierson; our products and services to you and otherwise fulfil our professional duties;  publicly available information searched as part of carrying out customer due  to improve, develop, market and diligence or as part of the provision of provide information about us and our our products or services to you; products and services (subject to any confidentiality requirements),  indirectly through your use of our including: website and the services and functionality offered through it; o working with you to develop ways in which we can improve our  the agents and service providers that products and services and the way we may engage to assist us with we deliver them, for you specifically fulfilling any of the purposes recorded and generally; and in this policy; and o addressing any particular matters  third parties connected with the you raise with us in connection with substance of the matter(s)/purpose(s) our products and services; for which you have engaged us.  for recruitment purposes, including The kind of personal information we assessing a candidate's suitability for a collect position with us; We collect only the personal information  to enforce our agreements with you (including for example your name, date of (including to supply, and invoice for, birth, address, email address, and contact products and services ordered by you, telephone numbers) you give us, and as and to collect payment); acquired through the other sources or means mentioned above. We may also  to protect our rights, property or safety keep a record of any information that you or those of third parties, including our acquire from us. employees, contractors, other clients, and users of our website or our If you are providing us with personal products or services; information about someone else, it may be  any specific purpose which we notify necessary to make sure that person is you of at the time personal information aware that our acting for you may involve is collected; and collecting, using, and disclosing their personal information. Please ensure you  to comply with any legal requirement, comply with your privacy obligations including any applicable law, court relating to the personal information of order, other judicial process, or the others that you provide to us. We can requirements of a regulator, and as discuss this with you if the matter arises. otherwise required or permitted by law. How we use, and may share, your personal In providing our products and services to information you, or in carrying out any of the other We use your personal information for the functions mentioned above, we may also following purposes: disclose your personal information to our contractors or agents, and other  to verify your identity, perform organisations, including: customer due diligence and for other administrative purposes;  other parties involved in the matter(s)/purpose(s) for which you  to reply to your queries;

have (or a client with whom you are information from the hardware and connected has) engaged us; software you use to access our website or receive our news updates.  identification verification and screening

agencies (each an intermediary) (who A cookie is a small data file that the website may temporarily hold such information sends to your browser, which may then for the purposes of process audit and store it on your system for later retrieval by error checking); the website. Cookies track your  any document issuer, official record movements through different websites; holder, credit bureau and authorised they do not record any other personal third parties' data providers (data information about you. Cookies are widely provider), for the purposes of customer used on websites to help with navigation due diligence (who may retain a record and to help personalise your experience of the fact that we or an intermediary when you visit a website. has requested a data comparison); We also use cookies in our electronic direct  credit reporting agencies (who may mail messages, including any newsletter retain the personal information we updates you may subscribe to. These share with them on their databases for cookies help us gain insight about the use in the provision of their credit content we send and how it is received, reporting services); which in turn helps us to improve the  third party service providers such as: content we create and the way we deliver it to you. o IT systems or services providers;

o data management, processing and If you reject cookies, you may still use our storage service providers; website and/or receive our electronic direct o auditors; mail messages, but your experience may be affected, and your ability to use some areas o banks and other financial service of our website may be limited. providers; o third parties engaged in the course To find out more about the way cookies of providing our services (such as work, how to see what cookies have been barristers, mediators, arbitrators, set and how to manage and delete them, witnesses and subject-matter visit www.allaboutcookies.org. To opt-out of experts); and being tracked by Google Analytics across all websites, visit o service providers that assist us with http://tools.google.com/dlpage/gaoptout. client insight analytics;  a court or tribunal; In addition to cookies, we use Google Analytics to understand and optimise user  regulatory and enforcement agencies; experience and to improve our advertising.  government agencies; and This tracking software collects and analyses certain types of information, including  as otherwise authorised by you. cookies, IP addresses, device and software We do not sell information that identifies identifiers, referring and exit URLs, onsite you personally. behaviour and usage information, and other similar information. We and Google How we use cookies and log files Analytics may also use cookies to anonymously track and target advertising We use cookies, log files and other based on your browsing behaviour. You technologies to collect personal

can see how Google uses data when you correct your personal information, your access our website here. correction request will be kept with the personal information held. We may use non-personalised statistics about the use of or website to monitor site How long we hold personal information traffic, to analyse trends, to gather We will keep your personal information demographic information about our user only for as long as necessary to achieve the base as a whole, to improve our website purpose for which it was collected. and to improve website user experience.

These anonymised and/or amalgamated If your personal information is no longer statistics do not comprise personal required by us, we will either destroy the information. information or de-identify it so it cannot be

attributed to you personally. Responsibility for personal information collected through linked third party Who you can contact for further websites information Our website, news updates or other If you have any queries about this Privacy communications to you, may contain links Policy or personal information we have to third party websites. Unless expressly collected, please contact: stated otherwise, these websites have not been developed by and are not controlled by us. They are provided for your Privacy Privacy Officer convenience only, and do not imply that we Contact check, endorse, approve or agree with the Person privacy practices of the third party websites Email [email protected] linked to. We encourage you to be aware address when you leave our website and to read the Address Simpson Grierson privacy statements of each and every Level 27 website that you visit. 88 Shortland Street

Auckland 1010 More information about our website, and New Zealand the terms of use applicable to it, can be found here. Postal Simpson Grierson Address Private Bag 92518 How you can access/amend your personal Wellesley Street information Auckland 1141 New Zealand You may request access to any of your personal information we hold by emailing us at [email protected]. Additional terms that apply to some Subject to any lawful grounds for residents of the European Economic Area withholding, we will provide you with a (EEA) copy of the personal information we keep In addition to the rights already recorded about you. above, if you are based in the EEA, you may have the following additional rights in You may request that the personal relation to the personal information we information we hold about you be hold about you: corrected by emailing us at [email protected]. If we  Right to erasure agree that your personal information is to You can ask us to delete or remove be corrected, we will do so. If we do not your personal information in some

circumstances, such as where we no process your personal information, longer need it or, if we are relying on except if we can demonstrate your consent to process the compelling legal grounds for the information, you withdraw your processing; or consent. If you are entitled to erasure o processing your personal we will comply with your request. If we information for direct marketing have shared your personal information purposes. with others, we will let them know about your request where reasonably  Right to withdraw consent possible. If you ask us, where it is If we rely on your consent as our legal reasonably possible and lawful for us to basis for processing your personal do so, we'll also tell you who we've information, you have the right to shared your personal information with withdraw that consent at any time. so that you can contact them directly.  Right to lodge a complaint with the  Right to restrict processing supervisory authority You can ask us to 'block' or suppress If you have a concern about any aspect the processing of your personal of our privacy practices, including the information in certain circumstances, way we've handled your personal such as where you contest the accuracy information, you can report it to the of that personal information or you do relevant Supervisory Authority in the not want us to erase your information EEA. but require restriction of processing Please be aware that some of these rights instead. If you are entitled to may be limited or unavailable where we restriction of processing of your have an overriding interest or legal personal information, and we have obligation to continue to process the data, shared your personal information with or where data may be exempt from others, we will let them know about the disclosure due to reasons of legal restriction where it is reasonably professional privilege or professional possible for us to do so. If you ask us, secrecy obligations. where it is reasonably possible and lawful for us to do so, we will also tell Your personal information may be you who we've shared your personal processed by our third party providers in information with so that you can Australia and Hong Kong. The European contact them directly. Commission has not recognised either  Right to data portability Australia or Hong Kong as providing You have the right, in certain adequate protection. We have enforceable circumstances, to obtain personal contractual arrangements with these third information you have provided us with party providers to ensure appropriate (in a structured, commonly used and safeguards are in place to protect your machine readable format) and to reuse personal information. Please email us at it elsewhere or to ask us to transfer this [email protected] if you to a third party of your choice. would like to obtain a copy of the safeguards in place with our third party  Right to object providers. You can ask us to stop processing your personal information, and we will do so, if we are: o relying on our own or someone else's legitimate interests to

BARRISTERS AND SOLICITORS

AUCKLAND: Level 27, 88 Shortland Street, Private Bag 92518, Auckland 1141, New Zealand. T +64 9 358 2222 WELLINGTON: Level 24, HSBC Tower, 195 Lambton Quay, PO Box 2402, Wellington 6140, New Zealand. T +64 4 499 4599 CHRISTCHURCH: Level 1, 151 Cambridge Terrace, West End, PO Box 874, Christchurch 8140, New Zealand. T +64 3 365 9914