Beaconpool is committed to safeguarding and processing personal information (“PI”), including sensitive personal information (“SPI”)1, in line with all applicable privacy and data protection laws. Many of our offices are located in countries with laws governing the processing of PI. “Beaconpool”, “we”, “us” or “our” means Beaconpool, Inc., and each of the direct or indirect subsidiaries of Beaconpool, Inc. (the “Beaconpool Group”). Beaconpool, Inc., Beaconpool Group functions and the entity you contract with are the controllers of your PI.

References to “you” or “your” refers to individuals whose PI is processed by Beaconpool, including individual investors, and client employees, officers or agents (together “Representatives”) with direct or indirect relationships (such as those who invest through an intermediary); and beneficial owners of an organization or entity in connection with:
* the provision of services to potential and actual clients;
* transactions to which we are party (including those which we effect on behalf of clients); or
* services provided to us by a third-party vendor.

References to “you” or “your” refers to individuals whose PI is processed by Beaconpool, including individual investors, and client employees, officers or agents (together “Representatives”) with direct or indirect relationships (such as those who invest through an intermediary); and beneficial owners of an organization or entity in connection with:
* the provision of services to potential and actual clients;
* transactions to which we are party (including those which we effect on behalf of clients); or
* services provided to us by a third-party vendor..

PI we collect about you
PI is information relating to an individual, which can be used either alone or with other sources of information to identify that individual. PI does not include information where the identity of the individual or the specific detail of the information has been removed and is therefore non-attributable. SPI is a sub-category of PI that includes PI relating to race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data.

The nature of the information that we collect will depend on the services provided, applicable laws and our relationship with you. We categorize the PI we may process as follows (the PI listed for each category are non-exhaustive examples):
* Identification data
Full name, title, gender, marital status, date of birth, passport number, driving license number, national identification number, signature.
* Contact data
Personal address, telephone number, email address
* Electronic Monitoring data
To the extent permitted by law, we may record and monitor your electronic communications with us.
* Financial data
Account number, client reference number; account statements, investment history.
* Marketing, Behavioral and Communications data
Marketing and communication preferences; information about your use of our websites, our portals and platforms as explained in our Cookie Notice.
* Professional Information data
Position/job title, business address, business telephone number business email address.
* Profile data
Username and password for our online services that you have access to, investments made by you, services requested, marketing communications responded to survey responses.
* Services data
Payment details to and from you, details of services you have provided to us, or we have provided to you.
* Beaconpool Building and Assets Security data
Records of visits to our premises, CCTV recordings.
* Technical data
Your use of and interaction with our online services, your IP address browser type and version, browser plug in types and versions operating system.
* SPI
In limited circumstances we may collect information about criminal convictions and offences, when legally required; dietary requirements, if we are arranging catering; disability, to make reasonable accommodations for you in our buildings; political affiliations, for us to determine whether you are a politically exposed person.

We collect PI in relation to you in several ways, including:
* Directly from you when provided to us in connection with a Beaconpool product or service; such as a completed investment application form.
* If you are Representative of an organization or entity that is a client or vendor of Beaconpool, and that organization or entity provides us with your PI.
* Throughout the course of our relationship with you, including where you change your details, provide additional PI, or where the services we are providing to you change.
* From public sources where you have been interacting with us via social media or where you have been notified that your PI is considered for talent acquisition purposes, including via public profiles on social media.
* From third parties such as credit reference agencies.
* From visits to our websites or through logging into any of our online services.

We may also create or derive PI such as creating records of your interactions with us, subject to applicable law. Unless we otherwise indicate that the provision of specific PI is optional, any PI we request is necessary for us to provide you or your organization or entity with the products and services requested. If you do not provide the PI requested, we may not be able to provide those products and services