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GENERAL PRIVACY POLICY

1. WHO WE ARE

We are Vistry Group PLC, a public limited company incorporated in England and
Wales (companynumber 00306718) with our registered officeat 11 Tower View, Kings
Hill, West Malling, Kent, ME19 4UY ('Vistry'). The VistryGroup is made up of
different legal entitiesthat we do business through,details of which can be
foundat this link (each a'Group Entity' or together, 'Group Entities').

The trading styles that we use are:

 * Bovis Homes
 * Linden Homes
 * Countryside Homes
 * Drew Smith
 * Vistry Ventures

This privacy policy is issused on behalf of the Vistry Group so when we mention
“Vistry”, “we”, “us” or “our” in the privacy policy,we are referring to the
relevant entity in the Vistry Group responsible for processing your data.

From time to time we will establish separate legal entities for our developments
with a third party, those entities own the properties on a development. Where we
establisha separate "legal entity" with a third party for a development, that
entity, us and the third party will be joint controllers of any personal data
collected in connection with the sale and marketing of those properties. You can
find a list of the separate legal entities that we have established here at this
link

1.1 Personal information relating to you from which you can be identified and
that we collector which you provide is referred to in this General Privacy
Policy as 'Personal Data'.

1.2 This General Privacy Policy provides general information about how Vistry
collects and uses Personal Data as a controller. Personal Data collected about
you, how is it used or shared, sources it may be obtained from and forwhat
purpose it may be used will also vary depending on the Group Entity you are
dealing withwho may act as a controller in respect of its processing as
described thereunder. You should therefore also review the specific privacy
policy that applies:

a) If you are a Bovis Homes customeror potential customer, by following this
link

b) If you are a Linden Homes customer or potential customer, by following this
link

c) If you are a Countryside Homes customer or potential customer, by following
this link

d) If you are a Drew Smithcustomer or potential customer, by following this link

e) If you are a Vistry Ventures customeror potential customer, by following this
link

f) If you are making a job application to a Vistry GroupEntity, by following
this link

(each is referred to as 'Entity Privacy Policy' or together 'Entity Privacy
Policies')

2. CONTACT

2.1 If you have queries regarding this General Privacy Policy or want to
exercise legal rights relating to your Personal Data (see 'Your Data Protection
Rights' below), please contact Vistry's data protection lead ('DPL') at:

2.2 Vistry Group PLC, Cleeve Hall, Cheltenham Road, Bishops Cleeve, Cheltenham,
Gloucestershire GL528GD data.protection@vistrygroup.co.uk

2.3 This General Privacy Policy and/or any of the Entity Privacy Policies may be
updated if there are any changes to Vistry's or a Group Entity's business,the
law or relevant privacy practices. You should check that you have seen the
latest version of this Privacy Policy or the Entity Privacy Policy that may
apply. If there are any significant changes, you may be informed of these
directly by post, email or another suitable medium.

3. WHAT WE USE YOUR PERSONAL DATA FOR

As well as the purposes referred to in each Entity Privacy Policy, Vistry may
use your Personal Data where:

a) You contact us (e.g.to make an enquiry or complaint) so that we can deal with
your issue orwhere we need to process such data when performing a task or
service involving you;

b) We provide direct marketing about products or services or provide corporate
information which may be of interest to you. Subject to applicable law, we may
do this by post, phone or electronically;

c) We need to establish, enforce or defend any of our legal rights or deal with
a legal claim;

d) We are required by applicable law, regulation, the order of any court or
regulatory authority; or

e) We have another purpose which you are notified about at the time we collect
the Personal Data.

4. LAWFUL GROUNDS ON WHICH VISTRYPROCESSES YOUR PERSONAL DATA

4.1 When we collect and process your Personal Data, we observe the UK General
Data Protection Regulation ('GDPR') and Data Protection Act 2018 ('DPA')
together with other applicable laws that regulate the protection of personal
data (as amended, updated or replaced from time to time) (together 'Data
Protection Law').

4.2 When we process your Personal Data, Vistry will rely on one or more of the
following lawful grounds:

a) To fulfil a contract we have with you (or to take steps at your request prior
to enteringa contract);

b) To comply with a legal obligation;

c) When Vistry (or someone else) has a legitimate interest to use such Personal
Data, subject to such use not having an unduly negative or unfair impact on your
privacy or prejudicing your rights and freedoms. In this case, the legitimate
interestis being able to process Personal Data for the purpose of us (or our
Group Entities) being able to effectively manage, organise and operate our/their
business;

d) When you consent to such processing or use;

e) To protect your vital interests or those of someone else, usually in cases of
life or death; and/or

f) When we are exercising a statutory function or official task in the public
interest, although this will only apply in exceptional situations.

For more information on the legal grounds that each Group Entity relies on,
including grounds on which theymay use special category or sensitive Personal
Data, please refer to the relevant Entity Privacy Policy.

5. DISCLOSING YOUR PERSONALDATA

5.1 Vistry may disclose your Personal Data to certain third parties who handle
data on our behalf and under contractonly in accordance with our instructions
(called 'processors') such as providers of IT support,data hosting or payment
processing services.

5.2 Vistry may also disclose your Personal Data to a Group Entity (for a purpose
as set out in the relevant Entity Privacy Policy) or to third parties who make
their own determination asto how they use your Personal Data and for what
purpose(s) such as a legal adviser or bank (who are acting as 'controllers' of
that data). More information on who those controllers are and what they do is
contained in the relevant Entity Privacy Policies. You should also check the
privacy policies of those third party controllers to understand how they may use
your Personal Data for their own purposes.

5.3 We may, very occasionally, transfer your Personal Data outside the UK or
European Economic Area ('EEA'). For example, we may do this: at your request;
when performing a contract with you or on your behalf; to comply with a legal
duty or in certain other situations where there is a reason to do so. When we
make such a transfer, we will comply with Data Protection Law which may include
us adopting adequate safeguards so that the transferred Personal Data is
protected to equivalent standards as you enjoy under Data Protection Law.

5.4 Other than as described above,Vistry will not disclose your Personal Data to
third parties without you reasonably expecting it, unless we are legally
required and cannot tell you. We aim to ensure that Personal Data is only used
by third parties with whom we share it in accordance with Data Protection Law.

6. PERSONAL DATARETENTION

Vistry only keeps Personal Data for a long as we need to. We have data retention
policies that set out the different periods we retain data for in respect of
particular processing purposes, in accordance with our duties under Data
Protection Law and other laws. Personal Data that we no longer need is erased or
anonymised so you can no longer be identified. For more information on the
retention criteria and practices of each Group Entity, please see the applicable
Entity Privacy Policy.

7. SECURITY

We employ appropriate technical and organisational security measures to protect
your Personal Data from being accessed by unauthorised persons; being unlawfully
processed; or from loss, destruction, or damage. Vistry also takes reasonable
steps to protect Personal Data from external threats such as hacking. However,
there are always risks in sending information by public networks or using public
computers and we cannot completely guarantee the security of all data sent to
us.

8. YOUR PERSONAL DATA RIGHTS

8.1 You have certain legal rights under Data Protection Law to the following:

a) To see a copy of the Personal Datat hat we hold about you as well as certain
other information about what we do with that Personal Data (called a
'subjectaccess request').

b) That we correct Personal Data that we hold about you which is inaccurate or
incomplete;

c) That we erase your Personal Data without undue delay if we no longer need to
hold or process it;

d) To object to automated processing that we may carry out in relation to your
Personal Data (if applicable) for example if we conduct credit scoring or
profiling with no human involvement;

e)To object to our use of your Personal Data to send you direct marketing;

f) To object to and/or to restrict theuse of your Personal Data by Vistry
unlesswe have a legitimate reason for continuing to use it for a particular
purpose or purposes; or

g) That we transfer your Personal Data to another party where such data is
automatically processed and has been collected with your consent or is being
used to perform a contract with you.

If you would like to exercise any of the rights set out above, please contact
our DPL at the address above.

8.2 If you make a request referred to above, we may first need to verify your
identity or receive further information to locate the specific data you seek
before we can respond in full. We usually have one month to respond from the
date of receiving your request (or, iflater, you verifying your identity or
providing the information to locate such data). We may, if your request is
complex in nature, require an additional two months to respond. We may lawfully
refuse a requestor charge for administrative time in the event of a manifestly
unreasonable or excessive (usually repeated) request. We may also apply certain
legal exemptions under Data Protection Law to limit our response. If you make a
subject access request, we have to balance your rights against the rights of
other individuals when your Personal Data is combined with their information.

8.3 If you make a request and are not satisfied with our response or believe
that Vistry is illegally processing your Personal Data, you have the right to
complain to the Information Commissioner's Office (ICO) – see
https://ico.org.uk/.


SHAREHOLDERS PRIVACY NOTICE

VISTRY GROUP PLC IS COMMITTED TO PROTECTING THE PRIVACY AND SECURITY OF YOUR
PERSONAL INFORMATION

Vistry Group will collect and use your personal information as described in this
Notice and as permitted by applicable laws, including in circumstances where:

 * it is necessary to fulfil our obligations to you as a shareholder
 * you have given us your express consent
 * it is necessary for one or more legitimate interests pursued by Vistry Group
   (or another party), so far as these do not unduly intrude on your privacy
 * Vistry Group is required to process your personal information in order to
   comply with a legal obligation

DATA PROTECTION PRINCIPLES

We will comply with applicable data protection law in the UK and other EU
territories where we operate ("Data Protection Law"). The principles of Data
Protection Law are that the personal information we hold about you must be:

 * Used lawfully, fairly and in a transparent way
 * Collected only for valid purposes that we have explained to you in this
   Notice or elsewhere and not used in any way that is incompatible with those
   purposes
 * Relevant to the above purposes
 * Accurate and kept up to date
 * Kept only for as long as necessary for our purposes
 * Appropriately protected against security risks

THE KIND OF INFORMATION WE HOLD ABOUT YOU

We may collect the following information about you:

 * Name, title, address, phone number and e-mail address
 * Date of birth
 * Identification documentation, such as passport information or National
   Insurance number
 * Bank account details
 * Shareholder records (including shares held, share purchases, share disposals,
   dividend entitlements and payments, votes, proxy appointments, shareholder
   options, exercise conditions and exercise dates)
 * Copies of enquiries, complaints and other correspondence and communications
   with you as a shareholder

HOW WE WILL USE INFORMATION ABOUT YOU

The personal information we collect will be held and processed by Vistry Group
for the following purposes:

 * To manage your shareholding interest in Vistry Group and our relationship
   with you as a shareholder, including:
 * to allow you to exercise your rights as a shareholder
 * to include you on our register of shareholders and maintain this and keep it
   up-to-date
 * to make dividend payments
 * to contact you with shareholder-related information, including shareholder
   announcements and information about dividend distributions, reports and
   meetings, including our Annual General Meeting
 * to provide information to Computershare Investor Services Plc
   (‘Computershare’), our registrars, so they can manage your shareholding on
   our behalf
 * For one or more of the following legitimate interests pursued by Vistry
   Group:
 * to produce and maintain shareholder records, announcements and communications
 * to review and respond to any enquiries and complaints you submit to us
 *  to conduct data analytics studies to review and better understand and
   monitor shareholder patterns
 * to manage and administer Vistry Group PLC’s business effectively
 * for proper record-keeping purposes relating to Vistry Group’s business and
   shareholdings
 * to comply with legal or regulatory requirements

SHARING YOUR PERSONAL INFORMATION

We may share your personal information with stock exchanges and regulatory
authorities to fulfil legal obligations that we are subject to.

We may share your information with other companies in our group, meaning Vistry
Group PLC, Vistry Homes Limited and each of its subsidiaries from time to time.
A complete list of the group companies is available on request.

We may share your data with third party providers such as Computershare and
others in order to communicate with any and all of the shareholders or who
provide support services to our business. These providers process your personal
information in accordance with our instructions and subject to data processing
agreements in accordance with applicable Data Protection Law.

TRANSFERRING YOUR INFORMATION OUTSIDE THE UK OR EUROPEAN ECONOMIC AREA ("EEA")

We may transfer personal information that we collect to selected service
providers, performing functions on our behalf, based in countries outside of the
UK or EEA.

Personal information stored in another jurisdiction may be subject to access
requests from governments, courts, or law enforcement in that jurisdiction
according to local laws. Whether the personal information you provide to Vistry
Group is processed by us or our service providers within the UK or EEA or
outside of it, we will use legally recognised data transfer mechanisms under
applicable UK or EEA data protection law to secure and safeguard this personal
information.

DATA RETENTION

We will only keep your personal information as long as you remain a shareholder
and for up to 10 years after you cease to be a shareholder. This will be for the
purpose of identifying, issuing or resolving legal claims and so we can comply
with applicable legislative and regulatory requirements for the keeping of
records.

Once personal information is no longer required to be retained by us, it will be
deleted or destroyed in an appropriate manner in accordance with applicable data
protection law.

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 keep us informed if your personal information changes during
your 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 other information about how we process it.
 * Request correction of any incomplete or inaccurate personal information that
   we hold about you.
 * Request erasure of your personal information where there is no good reason
   for us continuing to process it.
 * Object to processing of your personal information where we are relying on a
   legitimate interest. You also have the right to object to us processing your
   personal information to send you direct marketing.
 *  Request the restriction of processing. For example if there is a dispute
   about its accuracy or the reason for us processing it.
 * Request the transfer of your personal information to another party in certain
   circumstances.
 * Your right to withdraw consent. In circumstances where you have provided your
   consent to us processing your personal information for a specific purpose,
   you have the right to withdraw your consent for that specific purpose at any
   time.

To exercise these rights, please contact our Data Protection Team at the address
below.

CONTACTING OUR DATA PROTECTION TEAM

Our Data Protection Team oversees compliance with this Notice and Data
Protection Law. If you have any questions about this Notice or how we handle
your personal information, please contact the Data Protection Team at Vistry
Group PLC, Cleeve Hall, Cheltenham Road, Bishops Cleeve, Cheltenham,
Gloucestershire GL52 8DG or by email at

data.protection@vistrygroup.co.uk

If you feel that we are not processing your personal information in accordance
with Data Protection Law, you also have the right to make a complaint at any
time to the Information Commissioner’s Office (ICO).

See www.ico.org.uk/make-a-complaint

CHANGES TO THIS PRIVACY NOTICE

We reserve the right to update this Notice at any time by updating the version
on our website. In certain circumstances when we make any substantial updates to
this Notice, we may also notify you directly of these changes in writing.

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