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GDPR




PURPOSE

This privacy notice tells you what to expect when Numis collects personal
information. This applies to information we collect about:

 * Clients and prospective clients
 * Contacts at firms we deal with in both a client and non-client capacity
 * People who call us
 * People who e-mail us
 * Visitors to our website
 * Job applicants and our current and former employees
 * Speakers/presenters at meetings, presentations or seminars hosted or
   facilitated by Numis 

Numis is the controller for your personal data (which means we make decisions
about what information we collect about you, what it is used for and who we
share it with). Numis Securities Limited is registered with the UK Information
Commissioner’s Office (also known as the ICO) under registration number
Z7352263. 

Numis may use personal data to provide services requested from us, manage
accounts, make decisions, detect and prevent financial crime, for analysis and
assessment, and to ensure that we comply with applicable legal and regulatory
requirements. We do not pass your personal data to external marketers and would
not do so unless you have given us your explicit permission. 


WHAT IS PERSONAL DATA?

Personal data means information relating to an individual who can be identified
(directly or indirectly) from that information.
 
A further level of personal data is Sensitive, or ‘special category’ personal
data. The following data falls within this definition:

 * racial or ethnic origin
 * political opinions
 * religious or philosophical beliefs
 * trade union membership (or non-membership)
 * genetic data
 * biometric data
 * data concerning health 
 * data concerning a natural person's sex life or sexual orientation

Outside of the HR department, Numis records and retains very little data that
would constitute ‘sensitive personal data’ as it largely has very little
relevance to what we do as a business.


YOUR DATA RIGHTS

 * Under UK and EU data protection law, every individual has the following
   rights:
 * the right to be informed; - i.e. what data is being gathered and how it is
   being used and stored
 * the right of access; i.e. the right to see what personal data any company has
   relating to you
 * the right to rectification; e.g. ensuring data are accurate and up to date,
   and corrected if not•the right to erasure; - often referred to as ‘the right
   to be forgotten’ – erasure of all data at your request
 * the right to restrict processing; i.e. to limit data usage
 * the right to data portability; i.e. for your data to be sent to another
   company on your behalf, at your request
 * the right to object

Please note these rights may be superseded in some cases. For example, as a
regulated firm we have a legal obligation to retain records of clients and
trades. This legal obligation could mean that even if we are asked by a client
to erase or restrict their personal data, we may not be able to legally do so.
We may also not be able to provide all personal data held if doing so would
contravene the personal data rights of a third party. Each request will be dealt
with on a case by case basis.

In order to legally process personal data we need to rely on one or more of the
following conditions:

(a) Consent: the individual has given clear consent for you to process their
personal data for a specific purpose.
(b) Contract: the processing is necessary for a contract you have with the
individual, or because they have asked you to take specific steps before
entering into a contract.
(c) Legal obligation: the processing is necessary for you to comply with the law
(not including contractual obligations).
(d) Vital interests: the processing is necessary to protect someone’s life.
(e) Legitimate interests: the processing is necessary for your legitimate
interests or the legitimate interests of a third party unless there is a good
reason to protect the individual’s personal data which overrides those
legitimate interests. 
If we have obtained your consent to process your data, you have the right to
withdraw that consent at any time, at which point we will no longer be able to
process your data. Where appropriate, we include an unsubscribe link in the
footer of our marketing emails. In addition, should you wish to unsubscribe from
any email, or for any other data protection related query, you can contact us at
dataprotection@numis.com. 

Please note, however, that in cases where we have a legal obligation, we may
need to continue to process your data regardless of consent.


VISITORS TO OUR WEBSITES

For further information pertaining to Cookies and data stored across our
websites, please see our Cookie policy.
Visitors to numis.com
When someone visits www.numis.com we collect standard internet log information
and details of visitor behaviour patterns. We do not use this and it is only
processed in a way which does not identify anyone. We do not make or attempt to
find out the identities of those individuals visiting our website.


VISITORS TO NUMISCORP.COM

When someone visits www.numiscorp.com we use our third party web host E-Cube, to
collect standard internet log information and details of visitor behaviour
patterns. We do not use this and it is only processed in a way which does not
identify anyone. We do not make, and do not allow E- Cube to make, or attempt to
find out the identities of those individuals visiting our website. The only
exception to this is information about the publications downloaded by individual
users which we hold and process as personal information in line with our privacy
policy.


VISITORS TO CUSTODY.NUMIS.COM

Numis and Cytec Solutions Limited (“Cytec”) provide and maintain electronic
systems to administer and manage elements of its custodial services.  When
someone visits www.custody.numis.com, we use our third party web host Cytec, to
collect standard internet log information and details of visitor behaviour
patterns. We will hold and process any personal information in line with our
privacy policy that someone provides via the Custody Portal or by submitting
emails for the purposes of us providing custodial services. 


CLIENTS

Numis has legal obligations under applicable money laundering laws and
regulations to identify and verify its customers and perform ongoing monitoring
on customer data.  As part of customer identification (“KYC”) procedures Numis
collects personal information such as phone numbers, e-mail addresses and
financial details, along with identification information such as date of birth,
residential address and nationality. Numis may also hold personal information
obtained through publicly available sources such as credit agencies, media
publications and company registries. Some of the information we check is
sensitive personal data (known as special category data) such as your
nationality and any previous criminal convictions.

In the interests of fraud prevention and the prevention of financial crime(s)
your customer identification data will be shared with third parties who perform
monitoring services on behalf of Numis; these third parties are required to
adhere to the same high privacy standards as Numis.
Your personal data will only be shared in accordance with data protection laws
and where third parties are providing services to Numis as part of our ongoing
services and in order to satisfy our legal and regulatory obligations and/or
provision of our ongoing services to clients. 

Numis also utilises cloud storage solutions that may in some cases mean that
personal data will be stored on servers held in other countries, specifically
the USA. We also have contracts in place with some suppliers who work on our
data in order for us to be able to fulfil our contractual obligations –
specifically a firm in Sri Lanka which assists us with Singletrack software. As
with all our third party suppliers, they will be required to adhere to our high
standards of data privacy. We have a contract in place with all our suppliers
which contain data protection and confidentiality obligations. Where we transfer
outside the UK or the EU, we always have a mechanism in place to ensure your
personal data is processed safely.  If you would like any additional information
about which mechanisms we rely on for each of our suppliers, please contact us
at dataprotection@numis.com.


PEOPLE WHO CONTACT US

Contact information obtained by Numis as part of business related discussions or
data relating to existing client relationships may be held as part of our
records for as long as deemed necessary in order to further prospective and
ongoing client relationships.  Where contacted for marketing purposes these
individuals will be given the opportunity to have their information removed from
our records.  Otherwise information will be processed and deleted in line with
our retention schedule.

Via e-mail
Any email sent to us, including any attachments, may be monitored and used by us
for reasons of security and for monitoring compliance with company policy. 
Email monitoring or blocking software may also be used. Please be aware that you
have a responsibility to ensure that any email you send to us is within the
bounds of the law.

Over the Telephone
Numis records telephone calls as part of its ongoing regulatory obligations and
for monitoring and training purposes. These calls are kept for a pre-determined
amount of time; however this can be extended if our regulator makes such a
request.  The calls are stored securely and with limited access given to
specific employees.

Job Applicants, Current and Former Numis Employees
When individuals apply to work at Numis, we will only use the information they
supply to us to process their application and to monitor recruitment statistics.
Where we want to disclose information to a third party, for example where we
want to take up a reference or obtain a ‘disclosure’ from the Criminal Records
Bureau we will not do so without informing them beforehand unless the disclosure
is required by law.  These checks are facilitated by a third party who is based
in the EU and we expect to adhere to the same data privacy standards as Numis.
Personal information about unsuccessful candidates will be held and destroyed in
line with our retention schedule after the recruitment exercise has been
completed.  Some records are held to create a pipeline of talent for future
recruitment.  We may retain de-personalised statistical information about
applicants to help inform our recruitment activities, but no individuals are
identifiable from that data.
Once a person has taken up employment with Numis, we will compile a file
relating to their employment. The information contained in this will be kept
secure and will only be used for purposes directly relevant to that person’s
employment. Once employment with Numis has ended, we will retain the file in
accordance with the requirements of our retention schedule and then delete it.
Employees of Numis agree that their personal data will be used and shared in
accordance with our internal policies and that all correspondence made on work
equipment will be recorded in line with our regulatory requirements.
 
Data Retention
I.e. ‘how long we keep your data’. Numis retains personal data for set periods
of time. We have a data retention schedule which sets out what kind of documents
need to be retained, and for how long - different departments and paperwork are
subject to varying legal obligations. Once data has reached the end of its
retentions schedule it is safely destroyed. 
In exceptional cases, we may be required to keep your personal data for longer
than stated in our retention schedule (e.g. as evidence to help defend a legal
claim).

Organisational Security
Numis is committed to keeping your personal data safe and secure. Numis’ IT
department utilizes advanced software to keep out external threats. Every
employee has received face to face training on data protection, the importance
of people’s personal data, and the importance of records management and
archiving. Data is controlled by department, with access controls limited to
those employees who require it for a purpose. Physical security measures are
very strong, as to be expected for a regulated firm.

Complaints or Queries
Numis tries to meet the highest standards when collecting and using personal
information. For this reason, we take any complaints we receive about this very
seriously. We encourage people to bring it to our attention if they think that
our collection or use of information is unfair, misleading or inappropriate. We
would also welcome any suggestions for improving our procedures.

If you have any questions, please email dataprotection@numis.com This email
address is monitored by our Data Protection Manager. 

You have the right to complain directly to the relevant data protection
authority in respect of data protection matters. The UK regulator is the
Information Commissioner’s Office (ICO), and the Irish regulator is the Data
Protection Commission (DPC). We would hope to work with you to resolve any
issues prior to this step.

https://ico.org.uk/concerns
https://dataprotection.ie/en/individuals/exercising-your-rights/complaints-handling-investigations-and-enforcement-individuals

This privacy notice was drafted with brevity and clarity in mind. It does not
provide exhaustive detail of all aspects of Numis’ collection and use of
personal information, although it does not set out all of the purposes for which
such is collected and used. However, we are happy to provide any additional
information or explanation needed.
You acknowledge and agree that we may collect or use your personal data:
1.as may be required by law, including under anti-money laundering and terrorist
financing legislation;
2.to perform our obligations under any agreement we have with you and as you may
request from time to time, including the provision of the services to you;
3.to manage or administer the relationship between us and you;
4.to inform you about other products or services of any Numis group company
during the continuance of our relationship;
5.to assign or sub-contract, or procure goods or services, or to outsource any
part of the normal business functions of any Numis group company to third
parties;
6.to monitor our services, whether provided by ourselves or a third party;
7.to communicate with credit reference and information agencies to conduct our
KYC;
8.to share personal data with other Numis group companies, with our professional
advisers and other affiliated or non-affiliated business partners, or the
professional advisers and other affiliated or non-affiliated business partners
of another Numis group company, but only where the recipient has a legitimate
interest in the information disclosed to them; and
9.at your request or with your consent (e.g. marketing)

 * We are Numis
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London 45 Gresham Street, London, EC2V 7BF +44 (0) 20 7260 1000

New York 575 Fifth Avenue, 25th Floor, New York, NY 10017 +1 212 277 7300

Dublin Riverview House, 21 – 23 City Quay, Dublin 2, D02 FP21 +353 1 574 7200

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© 2020 Numis Securities Ltd

Numis Securities Ltd is authorised and regulated by the Financial Conduct
Authority (Firm Reference Number 144822).

Numis Securities Inc is a registered US broker-dealer and Member FINRA / SIPC.

Numis Europe Limited trading as Numis is regulated by the Central Bank of
Ireland.


We use cookies on our website to deliver the best possible experience. These
cookies are stored on your device and are defined as: “Essential” -- required
for the site to operate properly - these cookies will always be enabled when you
use the site; “Functional” – stores your preferences and optimise the experience
across the site; and “Performance” – provides us with analytics that we use to
improve site performance and usability. By clicking “Allow All” you are
consenting to our use of these cookies. You can view our full cookie policy –
and manage your cookie settings on this site – by clicking “Manage Preferences”.
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COOKIE POLICY

This policy describes how we, Numis, use cookies on all of our websites, namely
www.numis.com, www.numiscorp.com and www.custody.numis.com (“Websites”). In this
cookie policy, references to “we”, “us”, “our” and “Numis” mean Numis Securities
Ltd.

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 * ESSENTIAL
   
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   These cookies are essential for the operation of our Websites, or essential
   to the provision of the services you have requested. These include cookies
   that enable basic functions like remembering information you have entered on
   forms when you navigate to different pages in a single web browser session or
   allow you to stay logged in to your account. Our Websites cannot function
   properly without these essential cookies.
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 * FUNCTIONAL
   
   (Required)
   
   These are used to recognise you and your preferences when you return to our
   Websites. This enables us to provide you with a more personalised experience.
   These cookies are not essential for the operation of our Websites but they
   improve your experience of our Websites. If you block these cookies, you may
   have reduced functionality, or not be able to store personal preferences. 
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 * PERFORMANCE
   
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   These cookies help us improve our Websites by collecting and reporting
   information on how users move around our Websites, how long they spend on our
   Websites and which links they click. These cookies collect information in an
   anonymous form. If you block these cookies, we will not be able to improve
   our services as easily.
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NEW PARTNERSHIPS.
NEW OPPORTUNITIES.

October 2023

Numis is now part of Deutsche Bank, a global player in financial services with
150 years’ experience in creating value for clients in the UK.

Together we offer innovation, expertise and scale to deliver game-changing
solutions for ambitious UK companies and their investors.

With new ideas, new possibilities and new pathways towards success, we are a
leading force in UK investment banking.

We are Deutsche Numis.

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