REaD Ltd ("REaD Group") Privacy Policy covering data processing of business to business customer and prospect data

Effective Date: September 2020

1. Introduction

This privacy policy relates to how REaD Group uses business contact information that has been collected through a variety of mechanisms including the REaD corporate website, events, client or partner referrals or publicly available information. This information is collected for various purposes including the promotion of REaD Group and its products and services to business contacts.

Your privacy is important to us. This policy informs you what personal information we collect from you and how we use it.

2. Information We Collect

REaD Group collects your information to provide you with the best experience of our products and services. Some of this data will be provided by you, for example, when you complete a website contact form or hand a business card to us at events and some will be collected about you, for example, via cookies, from third party public sources or when you open one of our emails.

Information you provide to us:

information that you provide to us when contacting us through our websites (including name, address, email address, direct dial phone number, mobile phone number company/organisation name and job title);

information that you provide to us for the purpose of requesting information, including sales and marketing communications, subscribing to our email notifications or newsletters (including name, address, email address, direct dial phone number, mobile phone number company/organisation name and job title);

information contained in or relating to any communication that you send to us or send through our websites (including the communication content)

information you provide to us when entering a contractual agreement (including billing details and signature)

any other personal information that you choose to send to us.

Information that we collect about you:

metadata information about your computer and your visits to and use of our websites (as per our cookie policy). For example, when someone visits our websites we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various pages on our sites. This general information is only processed in a way which does not identify anyone. If you book a demo or request we contact you via our websites it is possible to link the online identifier to you and we would only use this information to better understand the pages you viewed on our site and the campaign that referred you to our sites. If an individual does not want us to be able to link them back to this information they can contact us directly on enquiries@readgroup.co.uk rather than completing the online form;

information about you that we collect from other public sources such as your Twitter Handle or LinkedIn Profile. For example, Company Name, Company Address, Sector, Job Title, Company Size and Birthday;

information provided to us by our email service provider which includes when you open one of our emails and the links you clicked on.

3. Use of Your Data

We will use your data for the purposes specified in this policy or the relevant pages of the websites in order to provide you with information, products and services that you have requested of us. We may also use your personal information to comply with our legal obligations.

3.1 We may use your personal information to:

(a) administer our websites, and business;

(b) personalise our websites for you;

(c) enable your use of the services available on our websites;

(d) send you email notifications, newsletters and sales and marketing communications;

(e) deliver a better or more tailored customer experience;

(f) deal with enquiries and complaints made by or about you relating to our websites;

(g) keep our websites secure and prevent fraud;

(h) verify compliance with the terms and conditions governing the use of our websites;

(i) to optimize our marketing campaigns;

(j) to meet any contractual obligations that we have agreed with you;

(k) to provide Customer Support, and the notification of any changes to REaD Group's products or services, solving issues via support portal, phone or email including any bug fixing.

4. Our Legitimate Interests

REaD has assessed that there is a legitimate interest to proactively share information on its products and services with you that are likely to benefit you and your organisation (of which you may not be aware in the absence of such communications).

REaD Group is a data communications business with expertise in data aggregation, data cleaning, analytics, insight, performance marketing, multi channel campaign execution, Single Customer View (SVC) builds and delivery via Data as a Service (DaaS). To grow and generate profits, REaD Group needs to sell and market its products and services to new potential customers (prospects), additional products and services to existing customers and attract partners who want to sell our products. Generating profits will enable REaD Group to contribute to the economy by paying taxes in the UK, pay its staff and reward them for the great work they do.

To achieve these aims REaD Group has a legitimate interest to process personal data to identify potential customers and partners who are in job roles that are likely to require its products and services and communicate this to them, either by phone, email or post. If you choose to object to these communications, we will update your permissions accordingly. To establish Legitimate Interest as a lawful basis for processing personal data for these purposes a Legitimate Interest Assessment was conducted and is available on request.

Subject to this, we will not, without your express consent, supply your personal information to any third party outside of the REaD Group for the purpose of their or any other third party's direct marketing.

5. Disclosing Personal Information

We may disclose your personal information to relevant parties as described in this policy.

5.1 We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.

5.2 We may disclose your personal information:

(a) to the extent that we are required to do so by law;

(b) in connection with any ongoing or prospective legal proceedings;

(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);

(d) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

5.4 Except as provided in this policy, we will not provide your personal information to third parties.

6. Data Storage

6.1 We use a select number of suppliers to support the provision of our services. For example, data is processed using a customer relationship management provider, email service provider and website host provider. Where we use any such sub-processors, we undertake prior due diligence to confirm that they meet recognised adequacy standards for data protection;

6.2 Personal information that you publish on our websites or submit for publication on our websites may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

6.3 You expressly agree to the transfers of personal information described in this Section.

7. Data Retention

7.1 This Section sets out our approach to data retention, which is designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.

7.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that specific purpose or those purposes.

7.3 Notwithstanding the other provisions of this Section, we will retain documents (including electronic documents) containing personal data:

(a) to the extent that we are required to do so by law;

(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and

(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

8. Security of Personal Information

We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

8.1 We will store all the personal information you provide on our secure (password- and firewall-protected) servers.

8.2 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

8.3 You are responsible for keeping the password you use for accessing our websites confidential; we will not ask you for your password (except when you log in to our websites).

8.4 REaD is certified to ISO27001.

9. Changes to This Policy

This policy may change from time to time. The latest effective date will be highlighted at the top of the policy information. We will update this privacy policy when necessary to reflect customer feedback, changes in our products and services or legal changes. When we post changes to this policy, we will revise the "Effective Date" at the top of the privacy policy and will describe the changes in the Change History page. If there are material changes to the privacy policy or in how REaD Group will use your personal data, we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to periodically review this privacy policy to learn how REaD Group is processing your information.

10. Your Control of Your Data

Managing how we contact you:

Your personal information belongs to you. You can adjust how we contact you for the purposes outlined in Section 3 by emailing us at marketing@readgroup.co.uk or by phoning us on 020 7089 6400. You can also write to us at:

REaD Group, The Pavilion, 1 Newham's Row, London SE1 3UZ

Managing your data:

10.1 You may request from us, details of the personal information we hold about you and how we are processing it.

10.2 Where notified, we will amend your data, including where you provide us with additional information to complete your record.

10.3 Where you have previously consented to REaD Group using your data, you may withdraw this consent at any time.

10.4 You may request that we restrict the use of your data, where you believe:

(a) the data we hold about you is inaccurate;

(b) the processing of your data is not lawful;

(c) your data no longer needs to be used for the purpose that it was originally provided;

(d) where you object to the use of your data for specific purposes.

10.5 You may have the right to request to transfer your data in a machine-readable format to your own store or another provider.

10.6 Should you no longer wish to engage with REaD Group, you may have the right to request erasure of your details from our systems.

To submit any such request, please send your request by email to marketing@readgroup.co.uk, or in writing to:

Data Protection Office

REaD Group, The Pavilion, 1 Newham's Row, London SE1 3UZ

11. Data Protection Registration

REaD Limited is registered as a data controller with the UK Information Commissioner's Office.

12. Our Details

The REaD Group website and its associated websites are owned and operated by REaD Group Ltd.

We are registered in England and Wales under registration number 2959244 and our registered head office is REaD Group, The Pavilion, 1 Newham's Row, London SE1 3UZ

You can contact us by writing to the business address given above, by using our websites' contact forms, by email to enquiries@readgroup.co.uk or by telephone on 020 7089 6400

WEBSITE TERMS AND CONDITIONS

Access to and use of www.ukchanges.com website("Site") is subject to the following Terms and Conditions and to the Privacy Policy both of which are available on the Site.

Capitalized terms used in this Terms and Conditions without definitions shall have the meanings ascribed to them.

1.Terms. Your use of this Site constitutes your acceptance in full of these Terms and Conditions(the "Terms and Conditions").Such acceptance shall take effect from the date that you first use the Site.REaD Group Limited("we", "us" or "REaD Group") operates this Site and reserves the right to change these Terms and Conditions at any time by posting changes online.REaD Group reserves the right, in its discretion, to suspend, change, modify, add or remove portions of REaD Group content available on the Site at any time and to restrict the use and accessibility of the Site.

You are responsible for reviewing information posted online to obtain timely notice of such changes.Your continued use of this Site after such changes are posted constitutes your acceptance of the Terms and Conditions as modified.

2.Use. Material may not be copied, reproduced, republished, downloaded, posted, broadcast or transmitted in any way except for your commercial use.Any other use requires the prior written permission of REaD Group.You agree not to adapt, alter or create a derivative work from any of the material contained in this Site.You agree to use this Site only for lawful purposes, and in a manner which does not infringe the rights of, or restrict or inhibit the use and enjoyment of this Site by any third party.Such restriction or inhibition includes, without limitation, conduct which is unlawful, or which may harass or cause distress or inconvenience to any person and the transmission of obscene or offensive content or disruption of normal flow of dialogue within this Site.When you visit this Site, or send emails to us, you are communicating with us electronically and we will communicate with you by email or by posting notices on the Site.You agree that all agreements, notices, disclosures and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing.

3.Liability. This Site and the information, names, images, pictures, logos and icons regarding or relating to REaD Group or its products and services or to third party products and services, are provided "AS IS" and on an "IS AVAILABLE" basis without any representation or endorsement made and without warranty of any kind whether express or implied, including but not limited to the implied warranties of satisfactory quality, fitness for a particular purpose, non - infringement, compatibility, security and accuracy.The Terms and Conditions do not exclude REaD Group’s liability(if any) to you for personal injury or death resulting from REaD Group’s negligence, for fraud or for any matter in respect of which it would be illegal for REaD Group to exclude or to attempt to exclude its liability.In no event will REaD Group and/or third parties be liable for any damages including, without limitation, indirect or consequential damages, or any damages whatsoever arising from use or loss of use, data, or profits, whether in action of contract, negligence or other tort action, arising out of or in connection with the use of the Site.REaD Group does not warrant that the functions contained in the material contained in this Site will be uninterrupted or error free, that defects will be corrected, or that this Site or the server that makes it available are free of viruses or bugs or represents the full functionality, accuracy, reliability of the materials.

4. Intellectual Property. The names, images and logos identifying REaD Group or third parties and their products and services are proprietary marks of REaD Group or third parties.Nothing contained herein shall be construed as conferring by implication, estoppel or otherwise any licence or right under any intellectual property of REaD Group or any other third party.Any feedback, comments or data submitted to the Site shall become the exclusive property of REaD Group.REaD Group does not permit copyright infringing activities and infringement of intellectual property rights on its Site, and REaD Group will remove the materials if properly notified that such material infringes on another’s intellectual property rights. REaD Group reserves the right to remove any materials on the Site without prior notice.

5. Accuracy of Information. The information in this Site is given in good faith and for general information and interest only.The results (if any) generated from this Site are based on the information you provide and statistics derived from materials and research undertaken by REaD Group or third parties in each selected industry using various suppression products.The results (if any) generated are illustrative only and are not guaranteed by REaD Group.Opinions, comments, references and any other contents at the Site are provided by us for informational purposes only

and are subject to change without notice.No information made available on the Site is for the purpose of providing accounting or consulting advice. Whilst every effort has been made to ensure the high quality and precision of the Site, REaD Group is not responsible for any inaccuracies and makes no representation and gives no warranty as to its accuracy.The information in this Site should not be relied on and does not constitute any form of advice or recommendation. By using this Site you confirm that you have not relied on any such information. Any arrangements made between you and any third party named or referred to on the Site are entirely at your sole risk and responsibility. As a result, you should not rely on this information, and we recommend that you take further advice or seek further guidance before taking any action based on the information contained on this Site.Our liability to you as explained in condition 3 remains unaffected by this.

6. Linking. This Site may contain links to other websites. REaD Group accepts no responsibility or liability for the content of other websites that are not under the strict control of REaD Group.Any link is not intended to be, nor should be construed as, an endorsement of any kind by REaD Group of that other website. It is your responsibility to check the Terms and Conditions, Privacy and Cookie policies on any other website which you visit.You may not create a link to this Site from another website or document without our express written permission.

7. No Contract for Services. Nothing on this Site is intended to be nor should be construed as an offer to enter into a contractual relationship with you or anyone else, except for those Terms and Conditions which govern the relationship between us in relation to your use of the Site.If you make a contract with a third party who is named or referred to on this Site, it is your responsibility to ensure that you are happy with that contract and to take legal advice if necessary.You agree and understand that while it may be possible to access and gather information through this Site, this does not constitute an incitement, invitation or personal endorsement in respect of the services or products provided by REaD Group or its affiliated or associated companies. Any potential benefits and advantages generated by this Site are illustrative based on the information provided by you and shall not be construed as a binding offer from REaD Group.

8. Content Standards. These content standards apply to any and all material which you contribute to this Site ("Contributions"), and to any interactive services associated with it. You must comply with the spirit of the following standards as well as the latter. These content standards apply to each part of any contribution as well as to its whole. Contributions must: i) be accurate (where they state facts); ii) be genuinely held (where they state opinions); and iii) comply with applicable law in the UK and in any country from which they are posted. Contributions must not: i) contain any material which is defamatory of any person; ii) contain any material which is obscene, offensive, hateful or inflammatory; iii) promote sexually explicit material; iv) promote violence; v) promote discrimination based on race, sex, religion, nationality, disability, sexual orientation or age; vi) infringe any copyright, database right or trade mark of any other person; vii) be likely to deceive any person; viii) be made in breach of any legal duty owed to a third party, such as a contractual duty or a duty of confidence; ix) promote any illegal activity; x) be threatening, abuse or invade another’s privacy, or cause annoyance, inconvenience or needless anxiety; xi) be likely to harass, upset, embarrass, alarm or annoy any other person; xii) be used to impersonate any person, or to misrepresent your identity or affiliation with any person; xiii) give

the impression that they emanate from us, if this is not the case; or xiv) advocate, promote or assist any unlawful act such as (by way of example only) copyright infringement or computer misuse.

9. General. If there is any conflict between these Terms and Conditions and rules and/or specific terms of use appearing on this Site relating to specific material then the latter shall prevail. If any of these Terms and Conditions or a portion thereof shall be determined to be illegal, invalid or otherwise unenforceable, then to the extent that such particular Terms and Conditions or portions thereof are illegal, invalid or unenforceable, they shall be severed and deleted and the remaining Terms and Conditions contained herein shall survive, remain in full force and effect and continue to be binding and enforceable. These Terms and Conditions shall be governed by and construed in accordance with the laws of England. The English courts shall have exclusive jurisdiction to settle any disputes that may arise out of or in connection with these Terms and Conditions. Failure to comply with the Terms and Conditions, the Privacy Policy and the Cookie Policy of this Site constitutes a material breach of the terms of use upon which you are permitted to use this Site, and may result in our taking all or any of the following actions: i) immediate, temporary or permanent withdrawal of your right to use this Site; ii) immediate, temporary or permanent removal of any posting or material uploaded by you on to this Site; iii) issue of a warning to you; iv) legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach; iv) further legal action against you; and/or v) disclosure of such information to law enforcement authorities as we reasonably feel is necessary. We exclude liability for actions taken in response to breaches of this Terms and Conditions and or Privacy Policy and or Cookie Policy. The responses described are not limited, and we may take any other action we reasonably deem appropriate.

10. Privacy Policy. Your use of the Site will also be governed by the Privacy Policy

11. Complete Agreement. These Terms and Conditions together with the Privacy Policy and the Cookie Policy contain all the Terms and Conditions which you and REaD Group have relied on and agreed to in relation to the use of the Site.

12. For further information from us contact us via post sent to the following address:

REaD Group Limited
The Pavilion
1 Newhams Row
Bermondsey Street
London
SE1 3UZ

13. REaD Group Limited is registered in England with its registered address at The Pavilion, 1 Newhams Row, Bermondsey Street, London, SE1 3UZ. Registered number 02959244.