Privacy Statement.

For the rest of this document Clearwater Growth will be referred to as Clearwater International.

Clearwater International (“we”, “us”, “our”) is committed to protecting and respecting your privacy. This statement sets out the basis on which any personal data we collect will be processed by us. Please read this privacy statement carefully to understand our views and practices and your rights regarding your personal data. By visiting www.clearwaterinternational.com (our website) your personal information will be processed as described in this statement.

Clearwater International is made up of different legal entities and partnerships registered in different jurisdictions, some of which are limited liability entities. This privacy statement is issued on behalf of all Clearwater International entities, and to the extent that we are a data controller.

The term “personal data” means any information relating to you such as name, contact details, contact preferences. It does not include data from which you can no longer be identified such as anonymous aggregate data.

Depending on your relationship with Clearwater International, the information maintained may include employment history, education information and other information as well as contact information. It may also include a record of our contact history with you and comments, views or references from third parties.

This data is stored in secure, proprietary and confidential databases which are accessible only by members of the Clearwater International team.

We will collect and process the following data about you:

• Information you give us. This is information about you that you give us by filling in forms on our site or by corresponding with us by phone, email or otherwise. The information you give us may include your name, job title, address, email address and phone number and financial information.
• Information we collect from your use of our site. With regard to each of your visits to our site we will automatically collect the following information: Internet protocol (IP) address used to connect your device to the Internet, whereabouts you connected to our service, your internet service provider (ISP), and what type of device you are using to access our service.
• Information we collect throughout our relationship. This is information relating to you, your role, your employment history, your personal interests and service usage data.
• Information we collect when you call us. If you call us we will automatically collect the following information: the phone number used to call us
• Information we receive from other sources. We carry out targeted research into companies which may benefit from our services and updates, based on specific sector and financial criteria. We will look to contact decision makers at these companies using personal data (including name, job title, contact details, employment history) gathered from publicly accessible sources such as search engines or websites. We do not undertake automated decision-making and do not intend to do so in future.

Providing us with your details online. This is information you may choose to provide us with using the contact forms on our site. It includes your name, address, telephone number, email address and preferences for receiving emails from us. Please let us know if any of this information changes so we can keep our records up to date.

We process your personal information for the following reasons:

• In accordance with a contract in order to:
  • process information at your request to take steps to enter into a contract;
  • provide you with our services;
  • process payments;
  • maintain business and service continuity;
  • send service communications so that you receive a full and functional service and so we can perform our obligations to you. These may be sent by email or post or, if the circumstances require it, we may contact you by phone. These will include notifications about changes to our service.

Failure to provide such personal data may lead to the above actions being delayed or may mean that we cannot provide our services.

Clearwater International has a legitimate interest in marketing our services to existing and potential clients and business contacts. Through our communications we provide information on M&A / debt funding opportunities and market trends.

In our legitimate interests of providing the best service and improving and growing our business we will process information in order to:

• provide you with a personalised service;
• provide you with information on market trends and opportunities;
• improve our services;
• keep our site and systems safe and secure;
• understand our customer base and purchasing trends;
• update and enhance client records;
• defend against or exercise legal claims and investigate complaints; and
• understand the effectiveness of our marketing.

We will carry out analytics to improve our services as set out above.

You have the right to object to processing carried out for our legitimate interests. See the What are your rights? section below for more information.

To comply with legal requirements relating to:

• the provision of services;
• data protection;
• health and safety;
• anti-money laundering;
• fraud investigations;
• assisting law enforcement; and

any other legal obligations placed on us from time to time.

We will keep information about you for as long as necessary to fulfil the purposes for which it was collected unless obligations to our regulators require otherwise or we are required to remove such data from our records. A copy of our data retention schedule can be provided upon request.

For the purposes set out in the ‘Why do we collect this information?’ section above, we will share your personal information with:

• the following categories of third parties, some of whom we appoint to provide services, including:
  • business partners, subsidiaries, suppliers and sub-contractors for the performance of any contract we enter into with you;
  • analytics and search engine providers that assist us in the improvement and optimisation of our site;
  • e-mail marketing platforms that assist us in sending electronic communications;
  • hosting services and content management systems that enable us to provide information through our website;
  • customer survey providers in order to receive feedback and improve our services.
• Any member of our group, which means our member entities.

Additionally, we may disclose your personal information to a relevant third party:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If we are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of our clients, our regulator, or others. (This includes exchanging information with other companies and organisations for the purposes of fraud protection and prevention of money laundering and credit risk reduction).

We will not lend or sell your information to third parties.

At Clearwater International, we take your safety and security very seriously and we are committed to protecting your personal and financial information. All information kept by us is stored on secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our service, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We may share your personal information with our service providers and this may involve transferring it to countries outside the UK, or with our overseas affiliate in China, whose data protection laws may not be as extensive as those which apply to us. Where we do so, we will ensure that we do this in accordance with the Acts and take appropriate measures to ensure that the level of protection which applies to your personal information processed in these countries is similar to that which applies within the UK. Such measures may include only transferring your data to jurisdictions in respect of which there is a European Commission adequacy decision or, where this is not the case, by using model clauses which have been approved by the European Commission.

We use our best efforts to ensure that data is accurate, complete, current and reliable for its intended use. We use appropriate technical and organisational measures and safeguards to help protect your personal data from unauthorised access, misuse, alteration or loss. Our internal policies and procedures are designed to help ensure we safeguard the privacy and accuracy of all data we collect or process. To the extent that we disclose personal data to clients or third parties, we will request that they properly protect the security and confidentiality of such information and otherwise process such data in accordance with applicable law.

You have the following rights. You can exercise these rights at any time by contacting us at Clearwater International, 6th Floor, 9 Colmore Row, Birmingham, B3 2BJ or gdpr@cwicf.com. You have the right:

• to ask us not to process your personal data for marketing purposes. We will inform you if we intend to use your data for such purposes;
• to ask us not to process your personal data where it is processed on the basis of legitimate interests provided that there are no compelling reasons for that processing;
• to ask us not to process your personal data for scientific or historical research purposes, where relevant, unless the processing is necessary in the public interest;
• to request from us access to personal information held about you;
• to ask for the information we hold about you to be rectified if it is inaccurate or incomplete;
• to ask for data to be erased provided that the personal data is no longer necessary for the purposes for which it was collected, you exercise your right to object, set out below, and there are no overriding legitimate ground for processing, the data is unlawfully processed, the data needs to be erased to comply with a legal obligation. When asked to remove a record from our database, Clearwater International will retain minimal information to ensure we do not contact you or collect such information again in future;
• to ask for the processing of that information to be restricted if the accuracy of that data is contested, the processing is unlawful, the personal data is no longer necessary for the purposes for which it was collected or you exercise your right to object (pending verification of whether there are legitimate grounds for processing);
• to ask for data portability if the processing is carried out by automated means and the legal basis for processing is consent or contract.

Should you have any issues, concerns or problems in relation to your data, or wish to notify us of data which is inaccurate, please let us know by contacting us at gdpr@cwicf.com.

This statement may be updated from time to time. Please check back frequently to see any updates or changes to our privacy statement.