This Privacy Policy is designed to help you understand what information we gather and process about you (“personal data”), why and how we use it, and with whom we share it. It also sets out the rights you have in relation to your information and how you may contact us for your queries.

DEFINITIONS USED IN THIS PRIVACY NOTICE CAN BE FOUND HERE

“Client” means an investor in our products or a recipient of our services, who may be an individual investor, or an employee, director, officer, trustee, beneficiary, or representative of an institutional or intermediary client of Brownstein capital.

“Secure Sphere Holdings”, “we” or “us” means Secure Sphere Holdings

“Secure Sphere Holdings Websites” means the websites operated by Secure Sphere Holdings

“Secure Sphere Holdings means the products and services that we offer to our Clients, including through our related support, mobile or cloud-based services.

“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Secure Sphere Holdings (or its representatives or service providers). In addition to factual information such as a name or address, it could include an expression of opinion about or an indication of intention in respect of an individual.

“You” means each individual to whom this notice is addressed, who may be:

(a) a Client or prospective Client of ours;

(b) a visitor to the Secure Sphere Holdings website; or

(c) an employee, director, officer or representative of another organisation with which we have a business relationship.

1. BACKGROUND

(1.1) Secure Sphere Holdings collects and uses certain Personal Data.Secure Sphere Holdings  is responsible for ensuring that it uses that Personal Data in compliance with data protection laws.

(1.2) At Secure Sphere Holdings, we respect Your privacy and we are committed to keeping your Personal Data secure.

(1.3) This Privacy Notice is directed to individuals whose Personal Data we handle in the course of carrying on our commercial activities. Those individuals could be Clients or prospective Clients or their representatives, agents or appointees, or an employee, director, officer or representative of another organisation with which we have a business relationship. This Privacy Notice is also directed to visitors to our websites.

2. OUR PRIVACY PROMISE

(2.1) To keep your Personal Data safe and private.

(2.2) Not to sell your Personal Data.

(2.3) To give you ways to manage and review your marketing choices at any time.

3. OVERVIEW OF CIRCUMSTANCES IN WHICH WE HANDLE YOUR PERSONAL DATA

(3.1) Secure Sphere Holdings gathers information about you in the following ways:

(a) Information we receive in the course of providing products or services to you. This may be provided directly from you or from third parties, such as providers of ‘know your Client’ and anti-money laundering services which we use to help us meet our legal obligations.

(b) Information we receive as part of your interest in our products or services. This is only provided by you and includes enquiries and other activities you perform while visiting our premises, participating in informative events and using Secure Sphere Holdings Websites. Details of how we handle the information we receive through our Websites are set out in paragraph 11 of this Privacy Notice.

We may combine the personal and other data we collect directly from you with information collected from or about you in other contexts, such as from our Web Sites or obtained from third parties.

4. THE TYPES OF PERSONAL DATA WE COLLECT

(4.1) In order to provide you with the correct service or product Secure Sphere Holdings needs to obtain and process Personal Data, such as:

a) Information that you provide to Secure Sphere Holdings. The nature of our relationship with you will determine the kind of Personal Data we might ask for. Such information may include:

* basic Personal Data such as first name; family name; national insurance number; email address; phone number; address (including city postcode and country); occupation and job title; bank details; ID documentation; date of birth; life events and family information;

* sensitive Personal Data, which may include information we handle about your racial or ethnic origin, health related information, disability status, trade union membership, genetic and bio-metric data or details of religious, political affiliations, or records of criminal offences and court proceedings.

b) We also process Personal Data about any person on whose behalf you are acting, for example investment beneficiaries, that you may have provided to us in connection with our provision of services to you. By providing us with their Personal Data, you agree to provide them with the information set out in this Privacy Notice.

c) Information that we collect or generate about you. This may include:

* files that we may produce as a record of our relationship with our Clients and prospective Clients, including contact history; and

* any Personal Data that you provide during communications with us which we may monitor and record in order to resolve complaints, improve our service and in order to comply with our legal and regulatory requirements; or

* any Personal Data that we obtain in relation to your use of Secure Sphere Holdings Websites (but this will be limited to the situations where users make themselves known by establishing a secure, authenticated session).

d) Information we obtain from other sources. Some of this Personal Data may be sensitive and may include:

* information from publicly available sources, including third party agencies such as credit reference agencies; fraud prevention agencies; law enforcement agencies; public databases, registers and records such as Companies House and the FCA Register; and other publicly accessible sources;

* information provided to us by independent financial advisors (IFAs), other professional advisers, product providers, event organisers, other agents and/or representatives, industry databases and other business intelligence tools Secure Sphere Holdings subscribes to; and

* information provided to us by companies or firms that introduce you to us

* information obtained from sanctions checking and background screening service providers.

5. HOW WE USE YOUR INFORMATION

(5.1) Your Personal Data may be stored and processed by us in the following ways and for the following purposes:

* to allow Clients and prospective Clients to use and access Secure Sphere Holdings Products and Services;

* to assess Client and prospective Client applications or contracts for Secure Sphere Holdings Products and Services;

* to set up / on-board prospective Clients to use Secure Sphere Holdings Products and Services;

* to keep our records up to date;

* to monitor IT systems in order to protect against cyber threats or malicious activity including abuse and misuse;

* to protect our premises from unauthorised access or use, or any unlawful activity ;

* to administer or maintain IT systems in order to uphold standards of service;

* for ongoing review and improvement of the information provided on Secure Sphere Holdings Websites to make them user friendly and prevent potential disruptions or cyber-attacks;

* to understand feedback on Secure Sphere Holdings Products and Services and to help provide more information on the use of those products and services quickly and easily;

* to communicate with and better understand the interests of Clients and prospective Clients in order to provide services or targeted information about Secure Sphere Holdings and other Secure Sphere Holdings Products and Services;

* to effectively manage and strengthen Client and prospective Client relationships, understand Client and prospective Client needs and interests and learn more about our Clients and prospective Clients in order to develop, improve and manage the products and services we can offer;

* for the management and administration of our business;

* in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or

* for the administration and maintenance of databases storing your Personal Data.

(5.2) When we use your Personal Data, we comply with applicable law. The law allows or requires us to use your Personal Data for a variety of reasons. These include instances where:

* we are performing our contractual obligations;

* we have legal and regulatory obligations that we have to discharge;

* we may need to do so in order to establish, exercise or defend our legal rights or those of our Clients or for the purpose of legal proceedings;

* we have obtained your consent;

* when it is in our legitimate interest

When we have a business or commercial reason of our own to use your information, this is called a ‘legitimate interest’. We will tell you what that is, if we are going to rely on it as the reason for using your data. Even then, it must not unfairly go against your interests.

(5.3) We may use systems to make automated decisions about you. This helps us to make sure our decisions are quick, fair, efficient and correct, based on what we know. Automated decisions can affect the products, services or features we may offer you now or in the future. They are based on Personal Data that we have or that we are allowed to collect from others.

6. WHO WE SHARE YOUR PERSONAL DATA WITH

(6.1) Your Personal Data may be shared with Secure Sphere Holdings plc, and entities within their respective corporate groups.

(6.2) We may also share your Personal Data outside of the Secure Sphere Holdings as further described below:

* with business partners of ours where they are contractually obliged to comply with appropriate data protection obligations;

* with representatives, agents, custodians, intermediaries and/or other third-party product providers appointed by the Client or prospective Client (such as accountants, professional advisors, custody service providers and product providers);

* with law enforcement and fraud prevention agencies as well as other financial services companies (to help prevent, detect and prosecute unlawful acts and fraudulent behaviour) . The personal information we have collected from you and anyone you have a financial link with may be shared with fraud prevention agencies who will use it to prevent fraud and money laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found here.

* with third party agents and contractors for the purposes of them providing services both to us (for example, Secure Sphere Holdings accountants, professional advisors, IT and communications providers, background screening providers, credit reference agencies and debt collectors) and to Clients or prospective Clients. These third parties will be subject to appropriate data protection obligations and due diligence;

* with any depository, stock exchange, clearing or settlement system, counterparties, dealers and others where disclosure of your Personal Data is reasonably intended for the purpose of effecting, managing or reporting transactions or establishing a relationship with a view to such transactions;

* where you are a joint account or portfolio holder (or otherwise one of multiple persons holding an account or portfolio), we may disclose your Personal Data to the other joint account or portfolio holder or other person;

* to the extent required by law or regulation, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with court order, tax reporting requirements and disclosures to regulators, auditors or public authorities), or to establish, exercise or defend its legal rights; and

* if we sell any part of our business or our assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes.

7. INTERNATIONAL TRANSFERS OF PERSONAL DATA

(7.1) Where we transfer your Personal Data to another country, we ensure that it will be protected and transferred in a manner consistent with legal requirements. In relation to data transferred outside of the UK and European Economic Area (the “EEA”), for example this may be done in one of the following ways:

* the country to which we send your Personal Data is approved by the European Commission as offering an adequate level of protection for Personal Data;

* the recipient signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging it to protect your Personal Data;

* in some limited circumstances the law may permit us to otherwise transfer your Personal Data outside of the UK and the EEA.

(7.2) You can obtain more details of the protection given to your Personal Data when it is transferred outside UK and the EEA by contacting us as described in paragraph 13 below

8. HOW WE SAFEGUARD YOUR PESONAL DATA

(8.1) Personal Data is a critical business asset and must be protected appropriate to its risk as well as its importance or value.

We ensure safe processing operations by operating and maintaining physical, electronic and procedural safeguards to guard your non-public Personal data and we restrict access only to authorised personnel. The effectiveness of these safeguards is periodically tested. We have extensive controls and mechanisms in place designed to detect, respond and recover in case of adverse events that may arise.

9. HOW LONG WE KEEP YOUR PERSONAL DATA

(9.1) The length of time for which we hold your Personal Data will vary as determined by the following criteria:

* the purpose for which we are using it (as further described in this Privacy Notice at paragraph 5.1) – we will need to keep the data for as long as is necessary for that purpose; and

* our legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.

10. YOUR RIGHTS

(10.1) In all the above cases in which we collect, use or store your Personal Data, you may have the following rights. You can exercise your rights free of charge in most cases. These rights include:

* the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;

* the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain your Personal Data to comply with a legal or regulatory obligation or to satisfy our internal audit requirements;

* in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit such data to a third party where this is technically feasible. Please note that this right only applies to Personal Data that you have provided directly to Secure Sphere Holdings;

* the right to request that we rectify your Personal Data if it is inaccurate or incomplete;

* the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data, but we are required or entitled to retain it;

* the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are required or entitled to refuse that request; and

* the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

(10.2) You can exercise your rights by contacting us on:

11. Secure Sphere Holdings WEBSITE

(11.1) If you use a Secure Sphere Holdings Website, we may collect technical information through the use of cookies. The type of information collected varies by category of cookies as explained in our Cookie Notice. As detailed in our Cookie Notice, we provide you with the opportunity to selectively accept certain categories of cookies in your Web browser through our Cookie Manager Application. If you accept cookies of the tracking category and you make your identity known during a secure (logged-on) browsing session on one of our Web Sites, we will be able to combine the information we collect about your usage of our Web Sites during that session with other information we know about you, such as any searches you conduct on our Web Sites or information you request during your web session. We will use this combined information to assess the appeal and usefulness of the information and tools offered on our Web Sites as well as to identify Secure Sphere Holdings products and services that may be of interest to you.

We also gather anonymous information related to browsing habits of users through other categories of cookies with the purpose of managing and improving our Website.

(11.2) If you use a Secure Sphere Holdings Website and follow a link from it to another website, different privacy policies may apply. Prior to submitting any Personal Data to a website, you should read the privacy policy applicable to that website

12. CHANGES TO THIS PRIVACY NOTICE

(12.1) Any changes we make to our Privacy Notice in the future will be posted on this website and where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Notice.

13. QUESTIONS AND CONCERNS

(13.1) If you have any questions or concerns about Secure Sphere Holdings handling of your Personal Data, or about this Privacy Notice, or to exercise any of your rights, please contact us at the address below.

To exercise your right to withdraw consent to receive electronic marketing communications at any time, please follow “unsubscribe” instructions found in such marketing materials.