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PRIVACY POLICY

Last updated March 2022

At OC&C Strategy Consultants we take your privacy seriously and we are committed
to protecting it.

This policy explains when and why we collect personal information about
individuals, how this information is used, with whom we share that information
and the rights they have over it. If you apply for a job vacancy with us,
details regarding our use of the personal information you provide to us is set
out in our separate OC&C Applicants Privacy Notice.

This policy may change from time to time so please check this page occasionally
to ensure that you are happy with any changes. This policy was last updated on
the date set out at the start of this page. Please see further the
section Changes to this policy below.

WHO WE ARE

We are an international consulting firm and operate our business through
numerous individual companies (each an "OC&C Company"). For a full list of these
companies please see the end of this policy. Whenever providing personal
information or interacting with one of our offices, the relevant OC&C Company
that corresponds to that office, as set out at the end of this policy, is the
‘controller’ in relation to the processing activities described below. A
‘controller’ is an organisation that decides why and how your personal
information is processed and is responsible for such processing.

Where this policy refers to "we", "our" or "us" below, unless it mentions
otherwise, it is referring to the particular OC&C Company that is the controller
of your personal information.

The version of our site located at www.occstrategy.com that we present to you
will depend on the location of the server from which you access it from, as we
aim to present the site in the local language of that location. The controller
of the personal information you provide to that site or that is collected when
you interact with it, is the OC&C Company listed at the end of this policy that
corresponds with the relevant version of the site presented to you.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect personal information from you in the following ways:

Personal information you give to us:

This is information about you that you give to us when:

submitting information via our site located at www.occstrategy.com, including
local versions and microsites (our "Websites");
following and posting on our social media pages;
corresponding with us by phone, email or in another way,
interacting with us at events;
providing us with your business cards;
we provide services to our client for whom you work;
we receive services from our supplier for whom you work; and
registering for and participating in our alumni network.
This information is provided by you entirely voluntarily and includes personal
information you submit on any web forms on our Websites, that you share by
posting to our message boards or to the alumni network using our Websites’
community features or that you provide to us in person (e.g. business cards). We
may also ask you for information when you report a problem with our Websites.
If, at our request, you complete any surveys for research purposes, we will
collect your personal information in such circumstances as well. The information
you give to us may include your name, address, email address and phone number,
enquiry details and other business and contact information, and may include
records of any correspondence and responses to any surveys.

If you do not give this information to us, you may be unable to use or interact
with certain parts of our Websites, communicate with us effectively, comply with
the contractual obligations that the organisation for whom you work is under or
allow us to comply with our own obligations if you work for an organisation that
is our client.

Personal information we collect about you:

We may automatically collect the following information during your visits to our
Websites: traffic data, location data, device data, weblogs and other
communication data, and details of the resources you access. We also
automatically collect technical information, including anonymous data collected
by the hosting server for statistical purposes, the Internet protocol (IP)
address used to connect your computer or device to the Internet, browser type
and version, time zone setting, browser plug-in types and versions, operating
system and platform. Please see our Cookies Policy for further information. We
may also collect any personal information which you allow to be shared that is
part of your public profile as an alumni or on third party social networks.

Personal information we may receive from other sources:

We obtain certain personal information about you from other sources (including
those outside of our business) which may include other OC&C Companies, our
suppliers and our clients. The sources that may send to us personal information
about you are as follows:

Source of personal information  The categories of personal information (as
described in the section below) that we obtain about you from this source Other
OC&C Companies  All categories Our suppliers  Behavioural, Biographical,
Contact, Correspondence, Identity, Employment, Fraud Our clients Behavioural,
Contact, Correspondence, Identity

CATEGORIES OF PERSONAL INFORMATION WE PROCESS ABOUT YOU

We process different types of personal information about you. To make it easier
to understand the information that we use about you, we have categorised this
information in the table below and provided a short explanation of the type of
information each category covers.

Category of personal information Description Behavioural your activities,
actions and behaviours Biographical your life experiences Contact information
which can be used to address, send or otherwise communicate a message to you
Identity information contained in a formal identification document or social
security or other unique reference relating to you Monitoring information
relating to the surveillance or monitoring of your activities Employment your
previous, current or future employment details Fraud information relating to the
occurrence, investigation or prevention of fraud Legal information relating to
legal claims made by or against you or the organisation for whom you work or the
claims process Correspondence information contained in our correspondence or
other communications with you or your work colleagues

HOW WE USE YOUR PERSONAL INFORMATION

The purposes for which we use your personal information and the legal basis
under data protection laws on which we rely to do this are explained below.

Where you have provided consent

We may use and process your personal information where you have consented for us
to do so. If you work for an unincorporated business, are a member of our alumni
network or a candidate interested in our recruitment efforts, we will contact
you via email or post with marketing information about our services if you (i)
register for an account with us online and indicate that you would like to
receive such marketing from us; (ii) sign up to insights (by email and/or post)
or news (by email) via our Websites or other medium where available; or (iii)
when you refresh your marketing preferences and opt-in when responding to a
request from us to do so.

You may withdraw your consent for us to use your information in any of these
ways at any time. Please see Withdrawing your consent for further details.

Where processing is necessary for us to pursue our legitimate interests

We may use and process your personal information where it is necessary for us to
pursue our legitimate interests as a business, for the following purposes:

Processing necessary for us to promote our services and our business

 * to create a profile of you and analyse this to obtain insight about market or
   industry trends, client behaviours which inform our marketing strategy, and
   to enhance and personalise your experience as a visitor (as well as the
   marketing information we contact you with in the ways described in the
   paragraph below);
 * if you work for a corporate business, to contact you by email or by telephone
   with marketing information about our products and services. We will use your
   personal information to tailor or personalise the marketing communications
   you receive to make them relevant to you;

Processing necessary for us to support our clients and prospects with sales and
other enquiries

 * to correspond and communicate with you when supporting you in connection with
   our services or your queries in relation to them;

Processing necessary for us to respond to changing market conditions and our
clients' needs

 * for market research in order to improve the services that we and other OC&C
   Companies deliver;
 * to notify you about changes to our services and our business;

Processing necessary to manage and administer our alumni network and prospective
recruits

 * to keep in touch with our alumni, and prospective recruitment candidates
   through non-promotional mailings, events and surveys;
 * to maintain and share marketing and career development contacts within the
   alumni network and with prospective recruitment candidates;

Processing necessary for us to operate the administrative and technical aspects
of our business efficiently and effectively

 * to administer our Websites and our social media pages and for our internal
   operations, including troubleshooting, testing and statistical reporting
   purposes;
 * to enable us to make payments to contractors and freelancers who provide
   services to us;
   for the prevention of fraud and other criminal activities;
 * to verify the accuracy of information we hold about you and create a better
   understanding of you as a visitor to our Websites;
 * for network and information security purposes in order for us to take steps
   to protect your information against loss or damage, theft or unauthorised
   access;
 * to comply with a request from you in connection with the exercise of your
   rights (for example where you have asked us not to contact you for marketing
   purposes, we will keep a record of this on our suppression lists in order to
   be able to comply with your request);
 * for the purposes of a corporate restructure or reorganisation or sale of our
   business or assets;
 * for efficiency, accuracy or other improvements of our databases and systems
   e.g. by combining systems or consolidating records we or other OC&C Companies
   hold about you;
 * to enforce or protect our contractual or other legal rights or to bring or
   defend legal proceedings; and
 * for general administration including managing your queries, complaints, or
   claims, to send service messages and to provide you with important
   information about our business.

Where required to comply with our legal obligations

We will use your personal information to comply with our legal obligations:

 * to assist any public authority or criminal investigatory body, where we are
   under a legal obligation to do so;
 * to identify you when you contact us;
 * to verify the accuracy of data we hold about you; and
 * to respond to and resolve your complaints in relation to our services.

OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION

Other OC&C Companies

We may share your information with other OC&C Companies. They may use your
personal information in the ways set out in How we use your personal
information, in connection with the services they provide, including where they
complement our own range of services.

Please see the end of this policy for the details of the OC&C Companies with
whom we may share your personal information, including their locations.

Our suppliers, service providers and other recipients

We may share your information with our third party service providers, agents,
subcontractors and other organisations (as listed below) for the purposes of
providing services to us or directly to you on our behalf.

Recipient / relationship to us Industry sector (& sub-sector)  Accountancy
services Professional services (accountancy) Banks, payment processors and
financial services providers Financial (banking) Cloud storage providers IT
(cloud services) Digital agencies Advertising (digital) Financial auditing
services Audit (financial) Government tax administration offices Government
(tax) Data deletion and archiving providers IT (data lifecycle management) T
support service providers IT (support and maintenance) Legal advisers
Professional services (legal services) On-site security access control services
Security (on-site)

The recipients mentioned above are located in Europe, USA and China.

When we use third party service providers, we only disclose to them any personal
information that is necessary for them to provide their service and we have a
contract in place that requires them to keep your information secure and not to
use it other than in accordance with our specific instructions.

When we share your personal information to third parties that are controllers of
that information, they may disclose or transfer it to other organisations in
accordance with their data protection policies. This does not affect any of your
data subject rights as detailed below. In particular, where you ask us to
rectify, erase or restrict the processing of your information, we take
reasonable steps to pass this request on to any such third parties with whom we
have shared your personal information.

Other ways we may share your personal information

We may transfer your personal information to a third party as part of a sale of
some or all of our business and assets to any third party or as part of any
business restructuring or reorganisation. We may also transfer your personal
information if we are under a duty to disclose or share it in order to comply
with any legal obligation, to detect or report a crime, to enforce or apply the
terms of our contracts or to protect the rights, property or safety of our
visitors and customers. We will always take steps with the aim of ensuring that
your privacy rights continue to be protected.

WHERE WE STORE YOUR PERSONAL INFORMATION

All information you provide to us may be transferred to countries outside the
European Economic Area (EEA). By way of example, this may happen where any of
the OC&C Companies are located in a country outside of the EEA or if any of our
servers or those of our third party service providers are from time to time
located in a country outside of the EEA. These countries may not have similar
data protection laws to the UK and so may not protect the use of your personal
information to the same standard.

If we transfer your information outside of the EEA in this way, we will take
steps to ensure that appropriate security measures are taken with the aim of
ensuring that your privacy rights continue to be protected as outlined in this
policy. These steps include

 * ensuring the non-EEA countries to which standards are made have been deemed
   adequately protective of your personal information for the purposes of data
   protection law by the relevant bodies;
 * mposing contractual obligations on the recipient of your personal information
   using provisions formally issued by relevant bodies for this purpose. We use
   these provisions to ensure that your information is protected when
   transferred to OC&C Companies outside EEA; or
 * ensuring that the recipients are subscribed to ‘international frameworks’,
   such as the EU-US Privacy Shield that aim to ensure adequate protection.

Please contact us using the details at the end of this policy for more
information about the protections that we put in place and to obtain a copy of
the relevant documents.

If you use our services whilst you are outside the EEA, your information may be
transferred outside the EEA in order to receive those services.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR

We do not retain personal information in an identifiable format for longer than
is necessary.

If we collect your personal information, the length of time we retain it is
determined by a number of factors including the purpose for which we use that
information and our obligations under other laws. We determine the period of
retention of your personal information based on the following criteria:

 * Retention in case of queries. We will retain your personal information in
   case of queries from you, including on behalf of an organisation for whom you
   work;
 * Retention in case of claims. We will retain certain of your personal
   information for the period in which you or a third party might bring claims
   against us;
 * Retention in accordance with legal and regulatory requirements. We will
   carefully consider whether we need to retain your personal information after
   the period described above in case of a legal or regulatory requirement

The exceptions to the above are where:

 * you exercise your right to require us to retain your personal information for
   a period longer than our stated retention period (see further Erasing your
   personal information or restricting its processing);
 * you exercise your right to have the information erased (where it applies) and
   we do not need to hold it in connection with any of the reasons permitted or
   required under the law (see further Erasing your personal information or
   restricting its processing below);
 * we bring or defend a legal claim or other proceedings during the period we
   retain your personal information, in which case we will retain your personal
   information until those proceedings have concluded and no further appeals are
   possible; or
 * in limited cases, existing or future law or a court or regulator requires us
   to keep your personal information for a longer or shorter period.

SECURITY AND LINKS TO OTHER SITES

We implement appropriate technical and organisational measures to keep your
personal information safe and secure.

Unfortunately, the transmission of information via the internet is not
completely secure. Although we will do our best to protect your personal
information, we cannot guarantee the security of your information transmitted to
our Websites and any transmission is at your own risk. Once we have received
your personal information, we put in place reasonable and appropriate controls
to ensure that it remains secure against accidental or unlawful destruction,
loss, alteration, or unauthorised access.

Our Websites may contain links to other websites run by other organisations.
This policy does not apply to those other websites‚ so we encourage you to read
their privacy statements. We cannot be responsible for the privacy policies and
practices of other websites even if you access them using links that we provide.
In addition, if you linked to our Websites from a third party website, we cannot
be responsible for the privacy policies and practices of the owners and
operators of that third party website and recommend that you check the policy of
that third party website.

COOKIES

Like many other websites, our Websites use cookies (including Google Analytics
cookies) to obtain an overall view of visitor habits and visitor volumes to our
website. 'Cookies' are small pieces of information sent to your computer or
device and stored on its hard drive to allow our websites to recognise you when
you visit.

It is possible to switch off cookies by setting your browser preferences. For
more information on how we use cookies and how to switch them off on your
device, please visit our Cookies Policy.

AUTOMATED DECISION MAKING

We do not envisage that any decisions that have a legal or significant effect on
you will be taken about you using purely automated means, however we will update
this policy and inform you if this position changes.

YOUR RIGHTS

You have a number of rights in relation to your personal information under data
protection law. In relation to certain rights, we may ask you for information to
confirm your identity and, where applicable, to help us to search for your
personal information. Except in rare cases, we will respond to you within one
month from either the date that we have confirmed your identity or, where we do
not need to do this because we already have this information, from the date we
received your request.

 * Accessing your personal information

You have the right to ask for a copy of the information that we hold about you
by emailing or writing to us at the address at the end of this policy. We may
not provide you with a copy of your personal information if this concerns other
individuals or we have another lawful reason to withhold that information.

 * Correcting and updating your personal information

The accuracy of your information is important to us and we are working on ways
to make it easier for you to review and correct the information that we hold
about you.

In the meantime, if you change your name or address/email address, or you
discover that any of the other information we hold is inaccurate or out of date,
please let us know by contacting us in any of the details described at the end
of this policy.

 * Withdrawing your consent

Where we rely on your consent as the legal basis for processing your personal
information, as set out under How we use your personal information, you may
withdraw your consent at any time by contacting us using the details at the end
of this policy. If you would like to withdraw your consent to receiving any
direct marketing to which you previously opted-in, you can do so using our
unsubscribe tool. If you withdraw your consent, our use of your personal
information before you withdraw is still lawful.

 * Objecting to our use of your personal information

Where we rely on your legitimate business interests as the legal basis for
processing your personal information for any purpose(s), as out under How we use
your personal information, you may object to us using your personal information
for these purposes by emailing or writing to us at the address at the end of
this policy. Except for the purposes for which we are sure we can continue to
process your personal information, we will temporarily stop processing your
personal information in line with your objection until we have investigated the
matter. If we agree that your objection is justified in accordance with your
rights under data protection laws, we will permanently stop using your data for
those purposes. Otherwise we will provide you with our justification as to why
we need to continue using your data. You may object to us using your personal
information for direct marketing purposes and we will automatically comply with
your request. If you would like to do so, please use our unsubscribe tool
included in all our marketing communications.

 * Erasing your personal information or restricting its processing

In certain circumstances, you may ask for your personal information to be
removed from our systems by emailing or writing to us at the address at the end
of this policy. Unless there is a reason that the law allows us to use your
personal information for longer, we will make reasonable efforts to comply with
your request. You may also ask us to restrict processing your personal
information where you believe it is unlawful for us to continue processing, you
have objected to its use and our investigation is pending or you require us to
keep it in connection with legal proceedings. In these situations we may only
process your personal information whilst its processing is restricted if we have
your consent or are legally permitted to do so, for example for storage
purposes, to protect the rights of another individual or company or in
connection with legal proceedings.

 * Transferring your personal information in a structured data file ('data
   portability’)

Where we rely on your consent as the legal basis for processing your personal
information or need to process it in connection with your contract, as set out
under How we use your personal information, you may ask us to provide you with a
copy of that information in a structured data file. We will provide this to you
electronically in a structured, commonly used and machine readable form, such as
a CSV file.

You can ask us to send your personal information directly to another service
provider, and we will do so if this is technically possible. We may not provide
you with a copy of your personal information if this concerns other individuals
or we have another lawful reason to withhold that information.

CHANGES TO THIS POLICY

We may review this policy from time to time and any changes will be notified to
you by email, where possible, or otherwise by posting an updated version of this
policy to our Websites. Any changes will take effect 7 days after the date of
our email or date of posting (as applicable), unless we state otherwise. We
recommend you regularly check for changes and review all updates to this policy.

CONTACT US

Please direct any queries about this policy or about the way we process your
personal information to our Chief Operating Officer using our contact details
below.

If you wish to write to us, please write to OC&C Strategy Consultants, 6 New
Street Square, London, EC4A 3AT or the applicable office address for the
relevant OC&C Company listed at the end of this policy.

Our email address for data protection queries is contact@occstrategy.com,
alternatively you can use our Contact Us form online.

If you would prefer to speak to us by phone, please call +44 20 70 10 8000.

OC&C Companies

OC&C Company Name Country Registered Address Registration Number Office Address
OC&C Strategy Consultants LLP UK 6 New Street Square, London EC4A 3AT OC323409 6
New Street Square, London EC4A 3AT OC&C Services Ltd UK 6 New Street Square,
London EC4A 3AT 02980806 6 New Street Square, London EC4A 3AT OC&C France SAS
France 36 rue Marbeuf
75008 Paris 831 537 147 RCS Paris 36 rue Marbeuf
75008 Paris OC&C Strategy and Analytics GmbH Germany Ludwigstraße 9, 80539
München, Deutschland HRB 236 847 Ludwigstraße 9, 80539 München, Deutschland OC&C
Strategy Consultants sp z.o.o Poland Piękna 18, 00-549 Warsaw 123 120 21 35
Piękna 18, 00-549 Warsaw OC&C Strategy Consultants USA Inc. USA 250 West 55th
Street, New York, NY 10019, USA EIN 47.525 2441 250 West 55th Street, New York,
NY 10019, USA OC&C Strategy Consultants China Unit 4, Block 3, No. 402 Zunyi
Road, Changning District, Shanghai, China 91310000MA1FW1MK30 1901-1911, 19F,
Shui On Plaza, 333 Middle Huai Hai Road,Huangpu District Shanghai, China 200021
OC&C Holdings Limited Hong Kong 17th Floor, Tower One, Lippo Centre, 89
Queensway, Hong Kong 2268959 15/F, On Building, 162 Queen's Road Central,
Central, Hong Kong
Greater China LTP S.r.l Italy Via Borgonuovo 14/16
20121, Milan PIVA IT10147540966 Via Borgonuovo 14/16
20121, Milan OC&C Strategy Consultants B.V. Netherlands Groothandelsgebouw,
Stationsplein 45 Unit C2.070, 3013AK Rotterdam 84069236 Groothandelsgebouw,
Stationsplein 45 Unit C2.070, 3013AK Rotterdam

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