Privacy Policy

BACK

1 WHO WE ARE

GAMARBRIDGE LLC is a Georgian limited liability company, which, together with entities controlled by GAMARBRIDGE or under common control with it (“we”, “us”, “our” or “GAMARBRIDGE”),offers research, sales, consultancy and funding services (“services”) to individual clients (private and professional), as well as to companies and institutional investors. Our registered office is: xxxxx xxxxx .

GAMARBRIDGE is the data controller responsible for the personal data that you provide to us.

We respect the privacy, and are strongly committed to protecting the personal data, of every person who visits the gamarbridge.com website (“our website”) including those who engage us to receive our services. We also safeguard any personal information provided to us by those applying to work at GAMARBRIDGE.

2 PURPOSE OF THIS PRIVACY POLICY

This privacy Policy (the “Privacy Policy”) explains: the nature of the personal data we might collect from you or which we have obtained about you from a third party; the purposes for which we process your personal data; our approach to protecting that personal data; and the rights you have, for example, to request that we delete, update, transfer or provide you with access to that personal data.

This Privacy Policy does not set out details of the personal data we hold in respect of persons that apply to work for us or how we process such data, as that information is set out in our Recruitment Privacy Policy.

3 HOW TO CONTACT US

If you have any questions about this Privacy Policy, or want to exercise your rights set out in this Privacy Policy, please contact us by:

- sending an email to dpo@gamarbridge.com;

- writing to us at our registered office address; or

- telephoning us on: +995 xxx xxxx

4 WHAT PERSONAL INFORMATION WE COLLECT ABOUT YOU

Personal information is information that can be used to identify you or that is about you. We collect, process and store different types of personal data, depending on whether you are a visitor to our website or offices, an existing or prospective client or investor, or a potential new recruit to GAMARBRIDGE.

The following is a non-exhaustive list of the personal information collected and processed as part of our business.

4.1 Visitors to our website

- Information about your interaction with the website (such as the number and frequency of visits you make to our website, your geographic location, your operating system and browser type and the search terms you use, which we receive via our technology tools);

- If you have registered on the website or requested further information in respect of our services: your name, job title, and contact information, including email address; and

- Other information relevant to our provision of services to you.

4.2 Visitors to GAMARBRIDGE offices

We require visitors to our offices to sign-in at reception. Visitors will be asked to give their name and the name of the entity for which they work, unless they are visiting our offices in a personal capacity (e.g. to attend a recruitment interview).

We have security measures in place at our offices, including CCTV and building access controls. There are signs in our office showing that CCTV is in operation and capturing your image.

4.3 Clients

Typically, we collect the following information about our clients who enter into a business relationship with us in order to use our services:

- identity, contact and background information, such as your name; job title; telephone number, postal address and email address; business and personal biographical and background information and information about your business and its employees/officers, as relevant;

- bank account details and other payment information;

- written and recorded telephone/video communications with you;

- other information relevant to our provision of services to you, including information we observe about you based on your interactions with our website;

- your consent, or otherwise, to receiving marketing material, and your preference for receiving such marketing – by telephone, email or post; and

- other relevant information as required by regulation and

- anti-money laundering regulations (or similar), for example, evidence of identity verification and financial information, including source of funds and assets held or under management

4.4 Attendees at events

We collect the following information about you if you attend one of our events:

- name, address and email address;

- written and recorded telephone communications with you;

- proof of identity, where required;

- your preference for attending certain types of event;

- your consent, or otherwise, to receiving marketing material, and your preference for receiving such marketing – by telephone, email or post; and

- special dietary requirements, where applicable.

4.5 Prospective GAMARBRIDGE job applicants

We collect personal data in connection with recruitment applications. We have set out the types of personal information that we collect and process for such purposes in our Recruitment Privacy Policy.

5 WHAT WE USE YOUR PERSONAL DATA FOR

We collect, process, maintain and store personal data from, and about, you:

- to verify your identity and to comply with obligations and policies relating to anti-money laundering, anti-bribery and ‘Know Your Client’ requirements;

- to manage and administer our relationship with our clients, their personnel and intermediaries;

- to monitor, improve and develop the quality of the services that we provide you;

- to carry out requests made by you on our website or in relation to our services;

- to record and monitor your visits to our website;

- to comply with applicable laws, court orders, other judicial processes, the requirements of any relevant regulator or our risk management obligations;

- to establish, exercise or defend our legal rights and/or for the purpose of legal proceedings;

- to protect the rights and property of us or third parties, including other clients and users of our website and services;

- for recruitment purposes; and

- to promote our services, including communicating our performance to you, sending you and your personnel marketing communications and other information that may be of interest and inviting you to events.

We may use your personal data for any other purpose if and to the extent that is required or permitted by applicable law.

You have the right to ask us not to send you marketing messages by post, telephone or email or any combination of these at any time.

You can do this by:

- unsubscribing by clicking on the relevant link included in a marketing email sent by us;

- sending an email to dpo@gamarbridge.com;

- writing to us at our registered office address; or

- by telephoning us on +995 xxx xxxx

6 THE LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA

We rely on the following legal grounds to process your personal data:

6.1 Performance of a contract

It is necessary for us to store and use your personal data to perform our obligations or exercise our rights, pursuant to and in accordance with any contractual arrangement that we may have with you.

6.2 Compliance with law or regulation

We may use your personal data in order to comply with applicable law or regulation, for example (but without limitation):

- to comply with our ‘Know Your Client’, anti-money laundering, anti-bribery and other similar legal obligations;

-to record any trades and transactions with you;

- to make any necessary corporate filings;

6.3 Legitimate business interests

We may process your personal information for our and others’ (including our clients’) legitimate business interests whilst applying appropriate safeguards that protect your privacy.

6.4 Your consent

Where our use of your personal information requires your consent, you can provide such consent:

- at the time we collect your personal information following the instructions provided; or

- by informing us by email or post using the contact details set out in this Privacy Policy.

7 COOKIES

Cookies are text files containing small amounts of information that are downloaded to your computer or other device when you visit a website - if your browser settings allow it. These cookies are accessed by the originating website on each subsequent visit.

Cookies are useful because they allow a website to recognise a user’s device and remember certain pieces of information that the user has provided to the website previously.

Where you have given your consent, we use cookies to collect personal information from the computer hardware and software or other device that you use to access our website, so that we can help provide you with the best possible online experience. This personal information includes:

- an IP address, to monitor our website traffic and volume;

- a session ID, to track usage statistics on our website; and

- information regarding your contact preferences and the interests you have shown in our services and products.

By using this information, we are able to measure the effectiveness of our content and how visitors use our website and our services.

You can manage cookies – for example, block or delete them – by adjusting the internet browser settings on your computer or other device.

8 SHARING DATA

We will only share personal data with trusted third parties pursuant to contractual arrangements or legal/regulatory obligations we have with or owe to them. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security policies.

We have set out below some of the third parties with whom we may share your personal information:

- third party systems providers - we use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them;

- other organisations that assist GAMARBRIDGE in providing or administering our services;

- companies that assist us with our marketing activities;

- our auditors, lawyers, accountants and other professional advisers;

- law enforcement agencies, branches of central and local government, and regulatory bodies/authorities;

- third parties involved in organising events or seminars; and

- third parties involved with the services we provide to clients, such as counterparties and their professional advisers and intermediaries, and courts, tribunals, public registrars and stock exchanges.

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable laws and regulations, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for access to personal data where we are permitted to do so in accordance with applicable laws or regulations.

9 TRANSFERS OF PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA

Where necessary, in order to deliver our services, we will transfer personal data to countries outside the EEA (including to GAMARBRIDGE, Inc.).When doing so, we will comply with our legal and regulatory obligations in relation to the personal information, including, but without limitation, having a lawful basis for transferring personal information, and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information so transferred.

10 HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We retain personal information about you for so long as it is required. When determining relevant retention periods, we take into account factors including:

- our contractual and business relationships with you and the purpose for which we hold your personal information;

- legal obligations to retain data for a certain period of time;

- relevant statutes of limitations;

- potential disputes;

- best practice; and

- guidelines issued by our regulator and relevant supervisory authorities.

After the relevant period has expired, we may destroy such files without further Policy or liability. If you request your files and documents we may charge you the reasonable cost of obtaining and providing you with such information.

11 CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION

We take the security of all the data we hold very seriously. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security. We regularly review the appropriateness of these measures to keep your personal safe and secure.

In particular, we have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

- unauthorised access;

- improper use or disclosure;

- unauthorised modification; and

- unlawful destruction or accidental loss.

All of our members, employees, workers, subcontractors, advisors, and any data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of, and comply with the policies that protect, all the personal information of visitors to our website and all users of our services.

12 HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS

Under certain circumstances, by law you may have the following rights in relation to the personal information we hold about you:

12.1 Your right of access

You may request access to your personal information and information about how we process it.

12.2 Your right to rectification

If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If you are entitled to rectification, and if we have shared your personal information with others, we will let them know about the required rectification, where possible. On request, and where possible and lawful to do so, we will inform you who we have shared your personal information with.

12.3 Your right to erasure

You may request that we delete or remove your personal information in some circumstances, such as where we no longer need it or if you withdraw your consent for us to process it (where you are entitled so to do). If you are entitled to erasure and if we have shared your personal information with others, we will let them know about the erasure, where possible.On request, and where it is possible and lawful for us to do so, we will inform you with we have shared your personal information.

12.4 Your right to data portability

In certain circumstances, you may request that we send you your personal information (in a ‘structured, commonly used and machine readable format’) such that you may re-use it elsewhere, or that we transfer it to a third party of your choice.

12.5 Your right to restrict or object to our processing of personal data

You may object to, or request the restriction of, our processing of your personal information.

12.6 Your rights in relation to automated decision-making and profiling

You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect – or similarly significantly affects you – unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

12.7 Your right to withdraw consent

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

If you want to exercise any of the above rights, please contact us at: dpo@gamarbridge.com.

13 COLLECTION OF INFORMATION BY THIRD-PARTY SITES AND SPONSORS

Our website contains links to other sites whose information practices may be different from our own. Visitors should consult the other sites' privacy Policies as GAMARBRIDGE has no control over information that is submitted to, or collected by, these third parties.

14 YOUR RIGHT TO LODGE A COMPLAINT WITH THE INFORMATION COMMISSIONER’S OFFICE

If you wish to request further information about any of the above, or if you are unhappy with how we have handled your information, please contact us at: dpo@gamarbridge.com

If you are not satisfied with our response to your complaint or believe our processing of your personal information does not comply with law, you can make a complaint to the Information Commissioner’s Office (ICO). You can contact the ICO using the following website https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

15 CHANGES TO THIS PRIVACY POLICY

To ensure that you are always aware of how we use your personal information, we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.